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****iC MEMORANDUM TO:

FROM:

SUBJECT.

UNITED STATES NUCLEAR REGULATORY COMMISSION

WASHINGTON, D.C. 20555-0001

October 26, 2011

David J. Wrona, Chief Project Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation

Lisa M. Regner, Sr. Project Manager i.'·- " Project Branch 2 ."

Division of License Renewal Office of Nuclear Reactor Regulation

SUMMARY OF PUBLIC SCOPING MEETINGS CONDUCTED ON SEPTEMBER 22, 2011, RELATED TO THE REVIEW OF THE LIMERICK GENERATING STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION

/!

~

The U.S. Nuclear Regulatory Commission (NRC) staff conducted overview and environmental scoping meetings related to the review of the Limerick Generating Station, Units 1 and 2 (LGS), license renewal applications submitted by Exelon Generation Company, LLC (Exelon). Two public meetings were conducted on September 22, 2011, at the Sunnybrook Ballroom, 50 Sunnybrook Road, Pottstown, PA 19464. Approximately 100 people attended the meetings.

The attendees included members of the NRC staff, members of the public, representatives from Exelon, news media, local and State government officials, and a representative of a U.S. Congressman. Public comments and questions were split between the benefits of nuclear power operation and its detriments. The environmental impact concerns mainly focused on water usage, water contamination, radiation risks, and severe accident impacts.

Two Public Meeting Feedback forms were received from the public. One form included environmental scoping comments and has been processed for consideration by the staff. The other form expressed appreciation of the tnformation presented by the overview and the supplemental literature provided during the open house.

A combined listing of attendees for both sessions is provided in Enclosure 1 Enclosure 2 is a copy of the meeting agenda. Enclosures 3 and 4 contain the official transcripts for the afternoon and evening meetings, respectively. Enclosure 5 contains a copy of the slides used dunng the NRC's presentation Enclosure 6 is a handout, provided at the: 'Yleetings.

Docket Nos. 50-352 and 50-353

Enclosures' As stated

cc w/encls. Listserv

LIST OF ATTENDEES LIMERICK GENERATING STATION, UNITS 1 AND 2, LICENSE RENEWAL

ENVIRONMENTAL SCOPING MEETINGS

SEPTEMBER 22, 2011

PARTICIPANTS Lisa Regner Robert Kuntz David Wrona Dennis Morey Rich Barkley Neil Sheehan Nancy McNamara Jo Ambrosini Nicole Sieller Kurt Imhof Thomas Quigley Michael Stokes Rich Janati Dave Allard Michael Murphy Terry Derstine Henry Tamanini Alan Brinser Eileen Dautrich Tim Fenchel Andrew Stein Traci Confer Jim Derr Jeff Norton Dr. Lewis Cuthbert Donna Cuthbert Vaughn Shirey Marisa Somich Andrew S. Fluck Sylvia Pollick Nancy Leaming Mellissa Anthim Nancy Ludwig Daniel Ludwig Camilla Lange Jay Beckman Jim Troutman Tom Lindauer Jeff Chomnuk Charlie Koenig David Trexler Nick Lampe Debra Kolarz Tom Wojton

AFFILIATION U.S. Nuclear Regulatory Commission (NRC) NRC NRC NRC NRC Region I NRC Region I NRC Region I NRC Resident Inspector Office NRC Resident Inspector Office U.S. Senator Robert Casey's Office State Representative Montgomery County Planning Committee PA Department of Environmental Protection PA Department of Environmental Protection PA Department of Environmental Protection PA Department of Environmental Protection PA Emergency Management Agency PA Emergency Management Agency Tri-County Area Chamber of Commerce Schuylkill River Heritage Area Sustainable Energy Fund Energy Justice Network Pottstown Energy Advisory Committee PA Energy Alliance Alliance for a Clean Environment Alliance for a Clean Environment Student Student Student Resident Resident Resident Resident Resident Resident Resident Resident Resident Resident Resident Resident Resident Resident Resident

ENCLOSURE 1

PARTieIPANTS Janet Stokes James Patrick John Matthews Marcy Matthews Judy Ferreri Dan Ely Gloria Romano Ray Romano Charlene Padworny Deb Schnidel Lorraine Ruppe Ed Gavin Dr. Fred Winter Joanne Kolsch Fred Van Ryn Thomas J. Neafcy, Jr. Bill Keohine C. T. Bossler Ed Keating Kevin Haslan Bill Albany Bill Vogel Julia Jackson Mr. & Mrs. Charles Shank Suzanne Tidmore Dorothy Barkley Rebecca Barkley Laura Fake P. Timothy Phelps Daniel Ely Ken Morgan Richard Kotsch Mike Gallagher

Bill McGuire Marshal Murphy Thom Chiomento John Hunter April Schilpp Jeanie Liggett Shannon Rafferty-Czincila Chris Wilson Nancy Ranek Leanne Birkmin Chris Conroy Bob Tarr Evan Brandt

2

AFFILIATION Resident Resident Resident Resident Resident Resident Resident Resident Resident Resident Resident Resident Resident Resident Resident Resident Resident Resident Resident Resident Resident Resident Resident Residents Resident Resident Resident Resident Resident Resident Retiree Retiree Exelon Generation Company, LLC (Exelon), VicePresident for License Renewal Exelon, Limerick Site Vice-President Exelon Exelon Exelon Exelon Exelon Exelon Exelon Exelon Exelon Exelon Exelon The Pottstown Mercury

3

John B. McGowan, Jr. Jaeco/GasBreaker/UMAC, Inc. Agron Cohen Excel Solutions PJ McGill MMI Engineering Thomas Saporito* Saprodani-Associates

* Per teleconference call

AGENDA FOR PUBLIC MEETING TO DISCUSS ENVIRONMENTAL SCOPING PROCESS FOR

LIMERICK GENERATING STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION

THURSDAY, SEPTEMBER 22, 2011

Two Meeting Sessions: 2:00 - 4:00 p.m. and 7:00 - 9:00 p.m.

I. Welcome and Purpose of Meeting 15 minutes (Richard Barkley)

II. Overview of Safety Review Process 15 minutes (Robert Kuntz)

III. Overview of Environmental Review Process 15 minutes (Lisa Regner)

IV. Public Comments As Required (Richard Barkley)

V. Closing/Availability of Transcripts 5 minutes (Richard Barkley)

*The NRC staff will host informal discussions one hour prior to each meeting session. No formal comments on the proposed scope of the Environmental Impact Statement (EIS) will be accepted during the informal discussions. To be considered, comments must be provided either at the transcribed public meetings (see agenda, above) or in writing, as described in the attached Federal Register Notice.

ENCLOSURE 2

October 26, 2011

MEMORANDUM TO: David J. Wrona, Chief Project Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation

FROM: Lisa M. Regner, Sr. Project Manager IRA! Project Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation

SUBJECT: SUMMARY OF PUBLIC SCOPING MEETINGS CONDUCTED ON SEPTEMBER 22, 2011, RELATED TO THE REVIEW OF THE LIMERICK GENERATING STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION

The U.S. Nuclear Regulatory Commission (NRC) staff conducted overview and environmental scoping meetings related to the review of the Limerick Generating Station, Units 1 and 2 (LGS), license renewal applications submitted by Exelon Generation Company, LLC (Exelon). Two public meetings were conducted on September 22, 2011, at the Sunnybrook Ballroom, 50 Sunnybrook Road, Pottstown, PA 19464. Approximately 100 people attended the meetings.

The attendees included members of the NRC staff, members of the public, representatives from Exelon, news media, local and State government officials, and a representative of a U.S. Congressman. Public comments and questions were split between the benefits of nuclear power operation and its detriments. The environmental impact concerns mainly focused on water usage, water contamination, radiation risks, and severe accident impacts.

Two Public Meeting Feedback forms were received from the public. One form included environmental scoping cornments and has been processed for consideration by the staff. The other form expressed appreciation of the information presented by the overview and the supplemental literature provided during the open house.

A combined listing of attendees for both sessions is provided in Enclosure 1. Enclosure 2 is a copy of the meeting agenda. Enclosures 3 and 4 contain the official transcripts for the afternoon and evening meetings, respectively. Enclosure 5 contains a copy of the slides used during the NRC's presentation. Enclosure 6 is a handout, provided at the meetings.

Docket Nos. 50-352 and 50-353

Enclosures: As stated

cc w/encls: Listserv

DISTRIBUTION: See next page ADAMS Accession Nos.: ML 11287A215(Pkg.), ML 11272A237(Sum.), ML 11287A207(Enc. 3), ML11287A211 (Enc. 4), ML 11264A012(Enc. 5), ML11287A214(Enc. 6)

"Concurrence via e-mail OFFICE LA: DLR/RPB2" PM: DLR/RPB1 PM DLR/RPB2 BC: DLR/RPB2 PM: DLR/RPB2

NAME IKing RKuntz LRegner DWrona LRegner

DATE 10/6/11 -..- ......

10/19/11 10/26111 ~~_.~"~~~C~OP~-~... ~

OFFICIAL RECORD COpy

10/26/11 10/26/11 i

Memorandum to David J. Wrona from Lisa M. Regner dated October 26, 2011

SUBJECT: SUMMARY OF PUBLIC SCOPING MEETINGS CONDUCTED ON SEPTEMBER 22, 2011, RELATED TO THE REVIEW OF THE LIMERICK GENERATING STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION

DISTRIBUTION:

HARD COPY: DLRRF

E-MAIL: PUBLIC RidsNrrDlrResource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRerb Resource RidsNrrDlrRarb Resource RidsNrrDlrRapb Resource DLR_RPOB Resource RidsOpaMail RidsOgcMailCenter

LRegner PBamford, DORL MSmith,OGC MBatY,OGC EDiPaolo, SRI JAmbrosini, SRI (A) NSieller, RI NMcNamara, RI DScrenci, RI NSheehan, RI

Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION Title: Limerick Generating Station License Renewal Public Meeting: Afternoon Session Docket Number: (n/a) Location: Pottstown, Pennsylvania Date: Thursday, September 22, 2011 Work Order No.: NRC-1128 Pages 1-77 NEAL R. GROSS AND CO., INC. Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

1

UNITED STATES OF AMERICA 1

+ + + + + 2

NUCLEAR REGULATORY COMMISSION 3

+ + + + + 4

PUBLIC MEETING TO DISCUSS THE LICENSE RENEWAL PROCESS 5

AND ENVIRONMENTAL SCOPING FOR LIMERICK GENERATING 6

STATION, UNITS 1 & 2 7

+ + + + + 8

THURSDAY 9

SEPTEMBER 22, 2011 10

+ + + + + 11

12

The Public Meeting met in the Sunnybrook 13

Ballroom, 50 Sunnybrook Road, Pottstown, Pennsylvania, 14

at 2:00 p.m., Richard Barkley, Meeting Facilitator, 15

presiding. 16

PRESENT: 17

RICHARD BARKLEY, Meeting Facilitator, NRC 18

ROBERT F. KUNTZ, Project Manager, NRR/DLR 19

DENNIS C. MOREY, Branch Chief, NRR/DLR 20

LISA M. REGNER, Sr. Project Manager, 21

NRR/DLR 22

DAVID J. WRONA, Branch Chief, NRR/DLR 23

24

PUBLIC COMMENTERS: 25


2

WILLIAM ALBANY, Limerick Township Police 1

Department 2

ANITA BALY 3

LEWIS CUTHBERT, Alliance For a Clean 4

Environment, PhD 5

EILEEN DAUTRICH, TriCounty Area Chamber of 6

Commerce 7

TIM FENCHEL, Schuylkill River National & 8

State Heritage Area 9

TED DEL GAIZO, Main Line Engineering 10

MICHAEL GALLAGHER, Exelon Nuclear 11

WILLIAM MAGUIRE, Exelon Nuclear 12

JOHN McGOWAN, UMAC 13

TOM NEAFCY, Limerick Township 14

TIMOTHY PHELPS 15

THOMAS QUIGLEY, Pennsylvania State 16

Representative 17

LORRAINE RUPPE 18

BILL VOGEL 19

FRED WINTER, MD 20

21

22

23

24


3

TABLE OF CONTENTS 1

Welcome and Opening Remarks, Richard 2

Barkley, Meeting Facilitator 4 3

Statement by Robert Kuntz, Project 4

Manager, NRR/DLR 7 5

Statement by Lisa Regner, Sr. Project Manager, 6

NRR/DLR 20 7

Public Comment Period 30 8

Adjournment 77 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24


4

P-R-O-C-E-E-D-I-N-G-S 1

2:04 P.M. 2

FACILITATOR BARKLEY: Good afternoon. 3

Wow. I'll try to get it adjusted to the sound system. 4

This is a great room, but I'm not used to such a 5

large venue to be speaking in. 6

My name is Richard Barkley. I'm the 7

meeting facilitator for this meeting and what I'd like 8

to do is just lead off initially with asking who in 9

the audience are members of an elected position with 10

either state, county, or local government? Would 11

somebody like to identify themselves? Go ahead. 12

MR. QUIGLEY: State Representative Tom 13

Quigley. 14

FACILITATOR BARKLEY: Thank you. 15

MR. NEAFCY: Tom Neafcy, Chairman of the 16

Limerick Township Board of Supervisors. 17

FACILITATOR BARKLEY: Thank you. Would 18

anyone else like to acknowledge themselves? Okay. 19

What I'd like to do quickly is just talk a 20

little bit about the ground rules for doing this 21

meeting as we go through. We have a lot of people who 22

want to speak, lots of issues to cover, so I need to 23

talk about how to make this meeting go fairly and so 24

that everybody is heard to speak as we go through. 25


5

1

I have a couple of ground rules that are 2

typically used at these meetings and they work very 3

effectively for me. One of them is asking you to sign 4

up on a speaker card or the sign-up sheet in the back 5

and so far I already have 16 people who have signed 6

up. So in the time allotted I'll have to limit you 7

about five minutes. Typically, I find -- yes, it was 8

a yellow card, but we still work with the same cards. 9

I would like to try to see if you can 10

finish your statement within five minutes. That's 11

typically what's needed to make a statement on an 12

issue and it's fair to everyone involved. If we go 13

through 16 speakers in five minutes with the 14

transition, we should finish right on time. 15

I'll try to call a couple speakers up so 16

that the first person who is coming up, the other two 17

people are kind of queued up and ready to go, so that 18

makes for a smoother and faster transition as we go. 19

And I try to alternate early on a little 20

bit to make sure our elected representatives get to 21

speak early on, but it's not all elected 22

representative speaking at the start, so we mix it up 23

a little bit. It seems to be one that's been 24

considered very fair to the audience. 25


6

Can we go to the next slide then, please? 1

I would ask you to silence all cell phones, please. 2

Please speak clearly into the microphone. 3

Again, I'm getting a strange echo in this hallway 4

here. We have fantastic acoustics, but it is going to 5

be a little awkward I think sound-wise. So try to 6

speak into the microphone clearly and we'll make 7

adjustments as needed as we go through. 8

I would ask in all fairness, please do not 9

interrupt the speaker when you're not at the 10

microphone, just in the interest of fairness. If we 11

for some reason don't get to all your comments or you 12

have more than five minutes of comments, I'll give you 13

a little bit of leeway, but if you have much more than 14

that I would ask that you turn it in in a written 15

form. If you are uncomfortable with speaking, you can 16

always turn your comments in in a written form and we 17

accept them and consider them the same way we do as a 18

verbal comment. 19

This meeting is a transcribed meeting. We 20

have a transcription specialist here and so we will 21

record all your comments and then address them in the 22

course of this proceeding. 23

And finally, if you have any questions 24

regarding the conduct of this meeting, you have some 25


7

issue with whether you get to speak or some issue of 1

fairness or you have a schedule constraint and you 2

need to speak earlier, please come see me. I'll be 3

standing over here to the corner. 4

With that, I'd like to turn it over to 5

Lisa Regner. Bob, do you want to -- yes. And Lisa 6

asked me that when you start out, please speak your 7

name clearly. That will help with the transcription 8

as he works through and tries to record all your 9

comments as clearly as possible. If you have your 10

comments all typed out and you're reading from a typed 11

arrangement, you're welcome to turn them into me and 12

I'll give them to the transcriptionist so that we 13

actually make sure we do this in a very clear and 14

precise manner. 15

With that, Rob Kuntz is going to go first. 16

Thank you. 17

MR. KUNTZ: Is this a good volume? Good. 18

Good afternoon. My name is Rob Kuntz. I 19

am the Safety Project Manager with the Division of 20

License Renewal and I am coordinating staff's review 21

associated with the Limerick Generating Station 22

license renewal application. 23

I'd like to thank you all for taking the 24

time to come out to our meeting this afternoon. 25


8

Today, we will provide an overview of the 1

license renewal review process which includes both a 2

safety and environmental review. We'll describe to 3

you the numerous ways and opportunity the public can 4

participation in the Limerick license renewal process 5

through either the safety or environmental component, 6

or both. 7

We also will describe in more detail the 8

environmental review process associated with license 9

renewal review. But the most important part of 10

today's meeting is to receive any comments that you 11

might have on the scope of the environmental review. 12

We also will give you some information about how you 13

can submit comments if you prefer not to speak at this 14

meeting. 15

At the conclusion of today's presentation, 16

we'll be happy to answer any questions that you may 17

have on the license renewal process. However, I must 18

ask you to limit your participation to questions only 19

and hold your comments until the appropriate time of 20

the meeting. Once all questions are answered, we can 21

begin to receive any comments that you have on the 22

scope of our environmental review. 23

Next slide. 24

Before I get into the discussion of the 25


9

license renewal process, I'd like to take a minute to 1

talk about the NRC in terms of what we do and what our 2

mission is. The NRC is a federal agency established 3

by the Energy Reorganization Act of 1974. We regulate 4

the civilian use of nuclear material. The Atomic 5

Energy Act of 1954 authorized the NRC to grant a 40-6

year operating license for nuclear power plants. This 7

40-year term was based primarily on economic 8

considerations and antitrust factors, not on safety or 9

technical limitations. 10

The Atomic Energy Act also allows for 11

license renewal. The National Environmental Policy 12

Act of 1969, often referred to as NEPA, established a 13

national policy for considering the impact of federal 14

decision making on the human environment. Lisa will 15

discuss NEPA in greater detail. 16

The NRC's regulations governing nuclear 17

safety, security, and environmental protection are 18

contained in Title 10 of the Code of Federal 19

Regulations, often referred to as 10 CFR. In 20

exercising its regulatory authority, the NRC's mission 21

is three-fold: to ensure adequate protection of 22

public health and safety, to promote a common defense 23

and security, and to protect the environment. 24

The NRC accomplishes its mission through a 25


10

combination of regulatory programs and processes such 1

as establishing rules and regulations, conducting 2

inspections, issuing enforceable actions, assessing 3

licensee performing, and evaluating operating 4

experience from nuclear power plants across the 5

country and internationally. 6

The NRC has resident inspectors at all 7

operating nuclear power plants. These inspectors are 8

on the front lines of ensuring acceptable safety 9

performance and compliance with regulatory 10

requirements. 11

Next slide. 12

Here's some background on the Limerick 13

license renewal. The license renewal application was 14

received by the NRC on June 22nd of this year. The 15

operating licenses for Unit 1 and 2 are set to expire 16

in 2024 and 2029, respectively. The licensee can 17

submit an application up to 20 years prior to the 18

expiration of their license, but they cannot be 19

granted a license for longer than 40 years. The 20

renewed license is superseding and it replaces the 21

existing license. 22

Next slide. 23

The first of the license renewal process 24

is to perform an acceptance and sufficiency review. 25


11

When the NRC receives a license renewal application, 1

the NRC staff examines it to determine whether the 2

application contains sufficient information to justify 3

the staff's review. The staff looks to see whether 4

the applicant has provided enough in terms of 5

technical information, technical specifications, and 6

the environmental report so that the staff can begin 7

its work, the application has enough in it to warrant 8

the staff's review. Then the application is 9

considered acceptable and sufficient and it is put on 10

the NRC's formal docket. 11

General information such as the 12

applicant's name and address, business and 13

administrative information, technical information 14

about plant structures and components and how the 15

applicant proposes to manage aging pertaining to aging 16

management. This information is the focus of the 17

staff's safety review. 18

Technical specifications define the 19

operating parameters of the plant. The application 20

indicates what, if any, changes or additions to 21

technical specifications are necessary to manage the 22

effects of aging during the period of extended 23

operation. The applicant also includes the 24

environmental report which is the applicant's 25


12

assessment of the environmental impacts of continued 1

operation. This information is the starting point for 2

the staff's environmental review which will be 3

discussed a bit later in the presentation. 4

Next slide. 5

I would like to mention a few very 6

important areas of NRC oversight that routinely come 7

up during our interactions with members of the public. 8

NRC staff addresses these areas of performance every 9

day as a part of the on-going regulatory oversight 10

provided for all currently operating power reactors. 11

They include current, safety performance as defined by 12

the NRC inspection findings, violations, and general 13

assessment of plant performance; emergency planning 14

and security. For specific information on current 15

performance of Limerick, you can use the link 16

provided on the slide. 17

The NRC monitors and provides regulatory 18

oversight of activities in these areas on an on-going 19

basis under the current operating license. Thus, we 20

do not reevaluate them in license renewal. That's not 21

to say that they're not important. We just do not 22

duplicate the regulatory process in this area for 23

license renewal. 24

Next slide. 25


13

Since the accident at Fukushima, the NRC 1

has taken multiple steps to ensure the safety 2

operation of nuclear power plants both now and in the 3

future. As part of its initial response to the 4

accident, the NRC issued temporary instructions to our 5

inspectors directing specific inspections in nuclear 6

power plants in order to assess disaster readiness and 7

compliance with current regulations. 8

The next step in the NRC's response was 9

the report of the NRC's Near-Term Task Force. The 10

purpose of the Near-Term Task Force was to develop 11

near-term recommendations and suggest a framework for 12

us to move forward in the longer term. The Near-Term 13

Task Force issued its report on July 12th of this year 14

and discussed the results of their review in a public 15

meeting on July 28th. As a result of the review, the 16

Near-Term Task Force presented 12 over-arching 17

recommendations for improvement. These 18

recommendations are applicable to operating reactors 19

regardless of license renewal status. 20

Based on the results of the Near-Term Task 21

Force, the Commission has directed the NRC staff to 22

evaluate and outline which of the recommendations 23

should be implemented. The staff submitted a paper to 24

the Commission on September 9th providing the staff's 25


14

recommendation on which task force recommendations, 1

and in the staff's judgment, should be initiated in 2

part or in whole without delay. On October 3

3rd, the staff will submit another Commission paper on 4

its prioritization of 11 of the 12 task force 5

Recommendation 1 of the task force, the 6

recommendation to reevaluate the NRC's regulatory 7

framework will be evaluated over the next 18 months. 8

To date, the NRC has not identified any issue as part 9

of these activities that call into question the safety 10

of any nuclear facility. Additionally, this review 11

process is going on independent of license renewal. 12

Any changes that are identified as necessary will be 13

implemented for all licensees regardless of license 14

renewal status. 15

More information on the NRC's post-16

Fukushima activities, including the results of the 17

Near-Term Task Force, can be found on the NRC's 18

website by clicking on the Japan Nuclear Accident NRC 19

Action Link on the home page or directly through the 20

web address on this slide. There are also a 21

limited number of copies of the Near-Term Task Force 22

report available at the back of the room. 23

Next slide. 24

Now on to license renewal process. Here's 25


15

a simplified diagram of the license renewal process. 1

The review involves two parallel reviews, the safety 2

review and the environmental review. These two 3

reviews evaluate separate aspects of the license 4

renewal application, but also features three other 5

considerations in the Commission's decision of whether 6

or not to review an operating license. 7

One of these considerations is the 8

independent review performed by the Advisory Committee 9

on reactor Safeguards or ACRS. Statutorily managed by 10

the Atomic Energy Act of 1954, the ACRS is a group of 11

scientists and nuclear safety experts who serve as a 12

consulting body to the Commission. The ACRS reviews 13

the license renewal application, the NRC's staff 14

evaluation, and inspection findings. The ACRS reports 15

their findings and recommendations directly to the 16

Commission. 17

Hearings may also be conducted if 18

interested stakeholders submit concerns or contentions 19

and their request for a hearing is granted. The 20

Atomic Safety and Licensing Board referred to as ASLB, 21

and adjudicatory panel will conduct the hearings. The 22

Commission considers the outcome of the hearing 23

process in its decision on whether or not to renew the 24

license. 25


16

As part of the environmental review, the 1

staff consults with state, local, federal, and tribal 2

officials such as the EPA and the staff holds public 3

meetings to receive comments on the Draft 4

Environmental Impact Statement. 5

Now I'm going to describe the license 6

renewal process in a little more detail, starting with 7

the safety review. 8

Next slide. 9

To better understand the license renewal 10

process, it's good to know the safety principles that 11

guide license renewal. The first principle is that 12

the current regulatory process is adequate to ensure 13

that the licensing basis for all operating plants 14

provides and maintains an acceptable level of safety. 15

The second principle is that the current plant's 16

specific licensing basis must be maintained during the 17

renewal term in the same manner and to the same extent 18

as during the original licensing term. In other 19

words, the same rules that apply under the current 20

license will apply on the renewal term. 21

In addition, a renewed license will 22

include conditions that must be met to ensure aging of 23

structures and components important to safety is 24

adequately managed so that the plant's current 25


17

licensing basis is maintained during the period of 1

extended operation. 2

The regulations governing license renewal 3

are based on two principles. To effectively 4

communicate these principles, I need to describe a 5

concept, a term of art used by the NRC. That concept 6

is licensing basis. Licensing basis consists of a 7

wide range of design and operational requirements and 8

conditions that must be met for the plant to comply 9

with its operating license. The primary focus of 10

these requirements is to maintain public health and 11

safety. They serve as the basis upon which the NRC 12

originally licensed the plant. To continue to 13

operate, the plant must conform with its licensing 14

basis. 15

Next slide. 16

The safety review focuses on the aging of 17

passive and long-lived structures and components and 18

systems that the NRC has deemed important to safety. 19

Components within the scope of license renewal are 20

defined in 10 CFR 54.4 and include safety-related 21

systems, structures, and components, nonsafety-related 22

systems, structures, and components whose failures 23

could prevent satisfactory accomplishment of safety-24

related SSC functions. And systems, structures, and 25


18

components relied on in its safety analysis or plant 1

evaluations to perform a function that demonstrates 2

compliance with the regulations for fire protection, 3

environmental qualification, pressurized thermal 4

shock, anticipated transients without scram, and 5

station blackout. 6

Passive components are components who 7

perform the functions without moving parts or change 8

in configuration or properties. Long lived are those 9

that are not replaced on qualified life or specific 10

time period. Active components are generally excluded 11

from license renewal because degradation is more 12

readily detected by existing surveillance and testing 13

and performance monitoring and condition monitoring. 14

The staff's main objective in this review 15

is to determine if the effects of aging will be 16

adequately managed by the applicant. The results of 17

the safety review are documented in a Safety 18

Evaluation Report. 19

Next slide. 20

A safety review comprises numerous 21

aspects. The technical staff reviews the application, 22

the applicant's license renewal application and 23

supporting documentation that determines the 24

applicant's methodology to identify the systems, 25


19

structures, and components within the scope of license 1

renewal and subject to an aging management review to 2

determine if the methodology has been properly 3

implemented and to determine with reasonable assurance 4

that the effects of aging for certain systems, 5

structures, and components will be adequately managed 6

or monitored by new and existing programs and 7

surveillance activities. 8

The staff uses site audits to verify the 9

technical basis of the license renewal application and 10

to confirm that the applicant's aging management 11

programs and activities conform with how they are 12

described in the application. The staff documents the 13

basis and conclusion of is review in a Safety 14

Evaluation Report which is publicly available. In 15

addition, a team of specialized inspectors travel to 16

the reactor site to verify that aging management 17

programs are being implemented, modified, and planned 18

consistent with the license renewal application. 19

Finally, as I've mentioned, the Advisory 20

Committee on Reactor Safeguards, the ACRS, performs an 21

independent review of the license renewal application, 22

the staff Safety Evaluation Report, and inspection 23

findings and makes a recommendation to the Commission 24

regarding the proposed action to issue a renewed 25


20

license. 1

Next slide. 2

This slide shows the important milestones 3

for the Limerick license renewal. Like I mentioned, 4

the application came in on June 22nd. Right now, 5

we're in the middle of the hearing process and that 6

runs through October 24th and that is the public's 7

chance to request the hearing and review of the 8

application. This meeting will serve as an 9

opportunity to solicit comment on the environmental 10

report, but you can continue to provide comment 11

through October 28th. The SER with Open Items, the 12

staff's evaluation is planned to be issued in July of 13

2012. 14

Let's see. And without a hearing, the 15

plan is to have a decision on the license renewal 16

application by April of 2013. 17

That concludes my portion of the 18

presentation. I'll turn it over to Lisa now. 19

MS. REGNER: Thank you, Rob. Can you hear 20

me okay? Good afternoon. As Rob said, my name is 21

Lisa Regner and my focus for the Limerick license 22

renewal review is on the environmental side. It's 23

equally important. It's separate from the safety 24

review that Rob talked about, but it's equally 25


21

important. 1

The review is performed in accordance with 2

the National Environmental Policy Act of 1969 or NEPA, 3

as Rob said. NEPA established a national policy for 4

considering environmental impacts and provides the 5

basic architecture for federal environmental reviews. 6

So all federal agencies are required to follow a 7

systematic approach in evaluating potential impacts of 8

projects and also to assess the alternatives to those 9

actions. 10

By law, the NEPA process involves public 11

participation and public disclosure. That's primarily 12

why we're here today. NEPA established the U.S. 13

Council on Environmental Quality, the CEQ, within the 14

Executive Office of the President. And the CEQ 15

establishes policy for how NEPA is to be implemented. 16

The NRC's environmental regulations are contained in 17

10 CFR Part 51 and they are largely based on those 18

that the CEQ developed. 19

Our environmental reviews considered the 20

impact of the license renewal and any mitigation for 21

those impacts that we consider significant. We also 22

consider the impacts of alternatives to license 23

renewal including the impact of not renewing the 24

license. The staff documents its environmental review 25


22

in an Environmental Impact Statement which is made 1

publicly available. 2

Ultimately, the purpose of the staff's 3

environmental review is to determine whether the 4

environmental impacts of license renewal are 5

reasonable and in combination with the safety review, 6

the regional inspections and decisions by the Advisory 7

Committee on Reactor Safeguards to make a 8

recommendation to the Commission whether to recommend 9

to renew the license or not. 10

Next slide. 11

So for a license renewal review, the NRC 12

environmental staff looks at a wide range of impacts. 13

Additionally, we consult with various federal, state, 14

and local officials, some of whom are here tonight, 15

we're happy to see, as well as leaders on tribal 16

nations. We gather pertinent information from these 17

sources and ensure it's considered in our analysis. 18

So some of the examples of the groups that we consult 19

with are the U.S. Fish and Wildlife Service, the 20

Environmental Protection Agency, and that includes the 21

Pennsylvania EPA as well who I'm happy to say is here 22

with us tonight; the Pennsylvania Department of 23

Conservation and Natural Resources, the Pennsylvania 24

Fish and Boat Commission, the State Historic 25


23

Preservation Office, and also Displaced Pennsylvania 1

Tribal Nations since you may or may not know there are 2

no tribal nations that exist in Pennsylvania, 3

federally-recognized tribal nations that still live in 4

Pennsylvania. But we do consult with those that have 5

been displaced. 6

Next slide, please. 7

The environmental review begins with a 8

scoping process which we're in the middle of right now 9

which is an assessment of the specific impacts and 10

significant issues that the staff should consider in 11

preparing the Limerick Environmental Impact Statement. 12

Information that we gather from you today and in the 13

next few weeks will be considered and included in the 14

Environmental Impact Statement. 15

We have recognized that some impacts are 16

similar, if not identical, at all nuclear power 17

plants, so to improve efficiency what we've done is to 18

develop a Generic Environmental Impact Statement or 19

GEIS, that addresses a number of impacts that are 20

common to all nuclear power plants. So what I will 21

prepare then with the staff is what we call a 22

Supplemental Environmental Impact Statement that's 23

specific to Limerick. But in addition to those site-24

specific issues, we also reexamine all the generic 25


24

issues for any new and significant information that 1

would change the conclusions in the GEIS, in the 2

Generic Environmental Impact Statement. 3


So the scoping period started on October 5

26th of this year when the Notice of Intent to prepare 6

an Environmental Impact Statement and conduct scoping 7

was published in the Federal Register. The NRC will 8

accept comments on the scope of the environmental 9

review until October 28th, so that's a few days more 10

than the hearing period which is different. Those are 11

two different dates, okay? So environmental comments 12

will be accepted until October 28th. 13

In general, what we're looking for in 14

those environmental comments is information about 15

environmental impacts from the continued operation of 16

Limerick. You can assist us in this process by 17

telling us, for example, what aspects of your local 18

community we should focus on, what local 19

environmental, social, and economic issues the NRC 20

should examine during our environmental review, what 21

other major projects are in progress or planned in the 22

area and what reasonable alternatives are most 23

appropriate for this region. 24

Those of us in license renewal are at 25


25

headquarters. We don't live in your community and 1

while we do have NRC people that do live in your 2

community, we need you to provide those regional 3

environmental impacts to us. That will help us do a 4

thorough and comprehensive review. 5

Those are just some of the examples of the 6

input we're looking for and they represent the kinds 7

of information we seek through the environmental 8

scoping process. 9


So this slide kind of ties it all 11

together. But I do want to stress if you look at the 12

top, public comments are an important part of the 13

environmental review process. How do we use your 14

comments? All of your comments to us whether provided 15

verbally during this meeting, in a written letter, 16

fax, or email are considered and addressed in our 17

Supplemental Environmental Impact Statement. We 18

respond to each comment as part of the SEIS and the 19

SEIS as well as several other factors shown here in 20

the slide will all contribute to the Commission's 21

decision whether to renew the Limerick license or not. 22


So how can you submit comments? Well, 24

first of all, those of you who are here and have 25


26

filled out the yellow card, you're good to go. We've 1

got the transcriptionist so all of those comments will 2

be accepted as formal comments. 3

Additionally, you can also go on line to 4

regulations.gov and it's a pretty easy process. If 5

you go to regulations.gov you'll see two search boxes. 6

If you put in this docket ID, NRC-2011-0166, 7

sometimes it takes a minute or at least for my 8

computer it takes a minute, you'll get a list of 9

hopefully Limerick-specific Federal Register notices. 10

The top one should be -- it should say Exelon 11

Generation Company, Notice of Intent to Prepare an 12

Environmental Impact Statement and Conduct Scoping 13

Process. And if you look on the right it should say, 14

it should have a link to submit a comment. If you 15

have any problems, my contact information is in here. 16

You can give me a call and I'll walk you through the 17

process. 18

Another alternative is fax. If you fax to 19

this number, you can reference RADB, that's just the 20

branch that collects and formally captures these 21

comments. You can also either reference the docket 22

number, that NRC 2011-0166 number or write Limerick, 23

okay? 24

As I mentioned, the deadline for comments 25


27

is October 28th. Next slide, please? 1

You can also submit by mail to this 2

address here and again they collect all the comments, 3

put them into our formal document management system 4

and they will be addressed by the staff. 5

Also, if you happen to be in Washington, 6

D.C. and want to come into NRC headquarters, you can 7

submit written comments in person as well. And you're 8

more than welcome to give me a call so that I can meet 9

you at the gate and help you with that, if you want to 10

come to headquarters. 11


So these are the environmental review 13

milestones. Again, scoping comments are due October 14

28th. Now this is not the last time that you'll see 15

myself or Rob. What we'll do is we will develop a 16

Draft Supplemental Environmental Impact Statement, as 17

I mentioned. We'll issue that formally, and anybody 18

that filled out a blue card and has an email address, 19

I will send that to you by email. And then we will 20

also have another public meeting where you can provide 21

comments on that Environmental Impact Statement. So 22

we'll be gathering again and that will happen barring 23

any unforeseen problems with this license renewal 24

application, we'll be doing that late August, early 25


28

September of 2012, next summer. 1

The final SEIS again, barring any 2

unforeseen problems that the staff identifies should 3

be right around February of 2013. And all of your 4

comments submitted in relation to the draft SEIS are 5

also addressed in the final SEIS. 6

Next slide, please? 7

Here's our, Rob's and my contact 8

information. We are the primary points of contact 9

within the NRC for license renewal issues at Limerick. 10

If it's not a license renewal issue, we'll do our 11

best to get you in contact with the appropriate 12

person. 13

Next slide. 14

Okay, if you don't happen to have a 15

computer, we've also provided a hard copy of the 16

license renewal application at two local libraries, 17

both the Pottstown Regional Public Library and the 18

Royersford Free Public Library have hard copies of the 19

license renewal application. They're pretty big. 20

It's two, four-inch, three-inch binders. So it's a 21

good -- three, three-inch binders. It's a good bit of 22

information. And that's both the safety and the 23

environmental report. I will also put the 24

draft SEIS in those libraries as well. 25


29

Additionally, I did bring a bunch of disks 1

that have it on disk if you would like to take the 2

license renewal application. They're in the back of 3

the room as well. 4

And I did want to do one more plug for the 5

blue cards, if you do have an email address and you 6

would like to receive any NRC-generated Limerick 7

documents that would include both license renewal and 8

non-license renewal NRC documents, we have a listserv 9

and if you give me your email address on one of those 10

blue cards, I can sign you up for that. 11

This concludes my presentation and I think 12

we will open it up for questions at this time. I'll 13

turn it back over to Rich Barkley. 14

FACILITATOR BARKLEY: Yes. At this point 15

in time before we move into the comments section, I 16

wanted to see if there were any questions regarding 17

the presentation made by the staff? So if you have a 18

question, raise your hand. I'll take the microphone 19

to you. If not, we'll move into the question and 20

answer period. 21

Okay, let's move into the question and 22

answer period. At this point in time, I have 16 23

people signed up. I was interested in three of the 24

speakers. I had three people from the National 25


30

Resources Defense Council signed up, but they were 1

thinking of actually turning their comments in in a 2

written form. So I wanted to see if they're here this 3

afternoon. And since they're not, then I have 13 4

people to go through in the call order. 5

So what I would like to do if we could is 6

have you make your statement from this fixed 7

microphone here in the middle of the hallway and I'd 8

like to lead off with Dr. Lewis Cuthbert, followed by 9

Bill MaGuire, the site vice president for Limerick 10

Station and then followed by State Representative 11

Thomas Quigley. 12

Mr. Cuthbert. 13

MR. CUTHBERT: Good afternoon, members of 14

NRC, elected officials and members of this community, 15

I'd like to read the following statement and then 16

place it on the record in hard copy with some 17

supporting documentation and research summaries, if I 18

may. 19

The Alliance for a Clean Environment has 20

conducted an 11-year investigation of the harms and 21

threats from Limerick Nuclear Power Plant. The body 22

of evidence confirms unprecedented environmental and 23

meltdown threats posed by this plant. One event, one 24

worst case scenario can trigger a catastrophe of 25


31

unthinkable proportions. Whether a natural disaster 1

or terrorist attack occurs, by relicensing Limerick, 2

NRC would in effect be placing Russian roulette with 3

the lives of more than eight million people. NRC must 4

close Limerick Nuclear Plant by 2029. 5

There is no way for either NRC or Exelon 6

to ensure the safety of the environment or the 7

residents impacted by this plant. It cannot be made 8

fail safe. No other facility has the potential to 9

render the entire region uninhabitable, possibly for 10

centuries as the result of an accident or terrorist 11

attack. This is the highest-risk facility that could 12

exist in any community in this country. 13

Current 40-year operating licenses expire 14

in 2024 and 2029. Why the rush to renew these 15

licenses now? 16

We urge the NRC to say no to Exelon's 17

requested license renewals. The public was led to 18

believe that Limerick's generators, fuel pools, and 19

miles of underground pipes and cables could operate 20

safely for 40 years and then the facility would close. 21

Is Exelon fearful that the longer they wait the more 22

serious problems may arise? 23

After only 26 of 40 years, numerous signs 24

of aging and risk have been identified. Corrosion, 25


32

deterioration, fatigue, cracking, thinning with loss 1

of material, loss of fracture toughness are all 2

documented in Exelon's own renewal application in the 3

aging management section. Instances of equipment 4

fatigue and cracking of vital equipment include the 5

reactor vessel and coolant system. 6

Aging equipment, after only 26 years 7

suggests that NRC should not just close the plant by 8

2029, but also ramp up their oversight vigilance 9

during the remaining 18 years of the current license. 10

In the past few years, Limerick has had numerous 11

unplanned shutdowns suggesting there are already 12

significant problems. Three occurred in one week in 13

June 2011. Loss of coolant leaks and accidents at 14

Limerick have already been documented. Serious 15

radioactive contamination could go undetected and 16

unreported for years from the corroding 17

infrastructure, much of it underground. 18

There have already been two near misses at 19

Limerick from 1996 to 2001. 20

This aging plant is an accident waiting to 21

happen. Large volumes, more than 6,000 assemblies 22

weighing more than a thousand tons of highly 23

radioactive waste in the form of spent fuel rods are 24

stored in densely-packed pools, elevated five stories 25


33

above and outside the reinforced containment 1

structure. This plant will produce about two more 2

tons of dangerous spent fuel rods every year that it 3

operates. Limerick, in addition, is now third on the 4

earthquake risk list for nuclear plants in the United 5

States. 6

With loss of cooling water, Limerick's 7

fuel rods could heat up, self ignite, and burn in an 8

unstoppable fire with catastrophic results. Exelon 9

has not been required to spend the money to guard 10

Limerick against terrorists, missiles, or air strikes 11

despite repeated requests to do so. 12

Dry cask storage and transport are also 13

very dangerous alternatives. It's time to close 14

Limerick and stop producing such deadly waste for 15

which there is no safe solution. As long as Limerick 16

operates harms to us and our environment will 17

increase. 18

Their harmful environmental impacts are 19

unprecedented. At the conclusion of our 11-year 20

investigation of routine radiation releases and review 21

of permits for major air pollution and a variety of 22

dangerous water contamination issues, it's clear that 23

this energy is not just dirty, it is in fact filthy. 24

Evidence that we've compiled has addressed a wide 25


34

range of topics: routine radiation releases into the 1

air, radioactive wastewater discharges into the 2

Schuylkill River, radioactive groundwater 3

contamination, radioactive nuclides associated with 4

the plant detected in our soil, our sediment, our 5

vegetation, our fish, our water, and milk. 6

Research has confirmed radiation in our 7

children's baby teeth in this community. Major air 8

pollution issues under health-based standards of the 9

Clean Air Act, 32 individual sources listed. Drastic, 10

harmful increases permitted in particulate matter 11

known also as PM-10 from the cooling towers, other air 12

pollution increases also permitted. 13

Dangerous depletion of the Schuylkill 14

River, in and by itself, a singular reason to deny 15

this permit. The Schuylkill is a vital drinking water 16

source for nearly two million people from Pottstown to 17

Philadelphia. It is being depleted and contaminated 18

every day that this plant operates. 19

Alarming cancer increases that have been 20

well documented in this community repeatedly far 21

higher than national and state averages after Limerick 22

started operating until the late 1990s. The 23

findings of our investigation lead us to conclude that 24

this plant is in common language a recipe for 25


35

disaster. 1

While NRC is required to prepare a 2

supplement to the Limerick Environmental Impact 3

Statement for license renewal, we have little 4

confidence in the process based on NRC's regulatory 5

history. It would be difficult to enumerate a short 6

list, so I'm going to rely on written documents. 7

There are critics of the NRC out there who have done a 8

much better job than we have of generating such a 9

list, most notably a scathing indictment by the 10

Associated Press. I'm not going to re-enumerate that 11

information. 12

It's long past time for the NRC to summon 13

the courage to do the right thing in our judgment and 14

actually protect the environment and the public, 15

rather than the industry. 16

Today, I am going to be submitting on the 17

record summary packets of our research on Limerick's 18

major air pollution, harms to the Schuylkill River, 19

radioactive groundwater contamination, links between 20

Limerick's radiation and our elevated cancers in this 21

community and how Limerick's nuclear power can, in 22

fact, be replaced with safer sources today. 23

Based on the compelling body of evidence 24

of environmental harms to date and the enormous 25


36

increased population in proximity to this facility, 1

Limerick Nuclear Plant must be closed by 2029. 2

There is no amount of energy production that is 3

worth risking the lives of so many people. Thank you 4

very much. 5

(Applause.) 6

FACILITATOR BARKLEY: Thank you, sir. 7

MR. MAGUIRE: Good afternoon. My name is 8

Bill Maguire and I am the site vice president at 9

Limerick Generating Station. And I have overall 10

responsibility for the safe and reliable operation of 11

the facility. 12

I have been working in the nuclear power 13

industry for 25 years and my career began at the 14

Limerick Generating Station as an engineer. I 15

continued with a license to be a licensed senior 16

reactor operator supervisor in the operations 17

organization and was the on-shift senior manager of 18

that facility for many years. 19

I have also worked at a few other nuclear 20

stations across the country and before rejoining 21

Limerick as the site vice president in May of 2010, I 22

was the site vice president at the Peach Bottom Atomic 23

Power Station in southeastern Pennsylvania in York 24

County. 25


37

Operating Limerick Generating Station 1

safely and reliably is a responsibility that everyone 2

at the power station takes very seriously. We 3

understand our obligation to the community, to the 4

environment, and to each other to operate the plant 5

safely. 6

A key component of a thriving community 7

like ours is the availability of safe, clean, and 8

reliable electricity. And as we look into the future 9

for the power needs of Pennsylvania and the United 10

States as a whole, we can see the increasing demand 11

for this very important resource. 12

At the same time, there's a growing 13

concern about greenhouse gases and climate change that 14

is a result of burning fossil fuels. To help meet 15

that growing power demand and to help keep our 16

environment clean, Exelon has applied to the U.S. 17

Nuclear Regulatory Commission for a 20-year extension 18

to the plant's operating license. Limerick's current 19

license for Unit 1 will expire in 2024 and Unit 2 in 20

2029. With license renewal, Limerick can provide our 21

region with clean power through 2049. 22

We understand our special obligation to 23

operate the plant safely and reliably and to maintain 24

a close relationship with our neighbors. We pledge to 25


38

continue that special trust as we operate the plant 1

well into the future. 2

The 104 nuclear reactors in the United 3

States provide roughly 20 percent of our nation's 4

electricity. More than 70 reactors nationwide have 5

already received approval from the Nuclear Regulatory 6

Commission for a 20-year license extension including 7

the Peach Bottom Atomic Power Station in York County. 8

Limerick Generating Station operates in a 9

manner that preserves the environment. The plant 10

produces almost no greenhouse gases. The plant 11

conducts approximately 1700 tests annually on air, 12

water, fish, soil, cow's milk, and other food products 13

to measure for environmental impact. We also maintain 14

a chain of radiation monitors surrounding the plant. 15

In 2005, the environmental management 16

systems at Limerick Generating Station achieved 17

certification under the strict criterion of the 18

International Organization for Standardization, ISO. 19

This certification is known as ISO 14001, a common 20

industry reference for the environmental 21

certification. The ISO 14001 certification requires a 22

commitment to excellence to prevent pollution and to 23

ensure continuous improvement in environmental areas. 24

In 2010, the Wildlife Habitat Council 25


39

recognized Limerick Generating Station's commitment to 1

environmental stewardship by awarding us the Wildlife 2

at Work Certification. This distinction was awarded 3

to Limerick Generating Station for our commitment 4

towards establishing long-term wildlife habitat 5

enhancements that provided undisturbed habitats with 6

food, water, cover, and space for animal species 7

living on the plant station's landscape. 8

To ensure Limerick continues to operate 9

safely for years to come, Exelon is investing in 10

upgrades to plant equipment. Since 2010, Exelon has 11

invested more than $200 million into the plant 12

including installation of new safety equipment, new 13

electrical cables, new valves, and refurbishing the 14

cooling towers. In addition, Limerick has made more 15

than $40 million in physical security upgrades since 16

2001. 17

Our investment in the future does not stop 18

with equipment. We have hired and trained over 100 19

new employees over the last three years, mostly coming 20

from our native region here. We maintain a steady 21

workforce of approximately 850 people and during our 22

annual maintenance and refueling outages, we bring in 23

between 1500 and 2000 temporary workers that provide a 24

boost to our local economy. Hiring and 25


40

retaining top talent is a key priority for Limerick 1

Generating Station. 2

Over the past 25 years, Limerick has been 3

one of the best performing and most reliable 4

generating stations in the nuclear power industry. 5

During that time, the plant has set several records 6

for continuous days of operation and has been 7

recognized by the industry for our reliable operation. 8

In March 2010, Limerick completed a successful run of 9

727 continuous days for our Unit 1 plant. This 10

represented the second longest continuous run for a 11

boiling water reactor in the United States. 12

While we do not set out to break records, 13

continuous operations are on indicator of the 14

excellent human performance and equipment reliability 15

that Limerick strikes for every day. 16

We also take pride in our investments in 17

the community. In 2010, Limerick donated more than 18

$600,000 to the community in contributions to the 19

United Way, fire and ambulance companies, educational 20

health and youth organizations. And many of our 21

employees serve as volunteers in the local communities 22

around the plant. 23

In conclusion, Limerick Generating Station 24

looks forward to working with the Nuclear Regulatory 25


41

Commission as you review our license renewal. I 1

appreciate the opportunity to speak with you this 2

afternoon. Thank you. 3

FACILITATOR BARKLEY: Thanks, Bill. 4

(Applause.) 5

FACILITATOR BARKLEY: Representative 6

Quigley. 7

REP. QUIGLEY: Good afternoon, my name is 8

State Representative Tom Quigley. I represent the 9

146th District here of which lower Pottsville is a 10

party of that district, so I want to welcome the NRC 11

here today to the beautiful Sunnybrook Ballroom for 12

this meeting and thank them for coming out to listen 13

to the public and take commentary. 14

I'm here today to voice my strong support 15

for the relicensing of the Limerick Generating 16

Station. I wanted to touch on a couple points of why 17

I feel it is important for this facility to be 18

relicensed. 19

First is the amount of electricity that is 20

produced by this facility. One of the things that 21

myself and my colleagues in Harrisburg hear 22

consistently from businesses and the Commonwealth and 23

our citizens is the demand for energy and electricity 24

now and more importantly what that demand is going to 25


42

be in the future. 1

Right now this facility generates enough 2

electricity for two millions homes and without 3

producing some of the greenhouse gases that we hear so 4

much about that could be produced by coal, natural 5

gas, or oil. And I'm going to put a caveat in there 6

for my good friends out in the western part of the 7

state where coal is a big part of the Pennsylvania 8

economy and I'm suggesting that this be done to the 9

exclusion of coal and nevertheless, some of the 10

technologies that they're developing out there are 11

also important for that industry and important for the 12

Commonwealth of Pennsylvania. 13

Again, one of the concerns we hear 14

consistently from businesses is how can we come here 15

into Pennsylvania with the infrastructure being what 16

it is which needs to be improved for the transmission 17

of the electricity, but more importantly the 18

generation of that electricity? 19

Number two, I think is important is the 20

jobs and overall economy. Again, in these tough 21

economic times that we're facing here in the 22

Commonwealth of Pennsylvania and also in this nation, 23

one of the top issues that we hear consistently about 24

is jobs. 25


43

And as was mentioned by the site vice 1

president, over 860 people are employed here with an 2

annual payroll of $75 million. The direct impact that 3

is to the Commonwealth of Pennsylvania, of course, is 4

realized through the state income tax and also all of 5

these local municipalities most of them enact an 6

earned income tax which again sustains their townships 7

as well as their respective school districts. To have 8

that taken away I think would have an even more 9

dramatic impact on our local economy. 10

As was mentioned the impact for the local 11

area here, the temporary workers who show up here 12

during the outages and the refueling, there's already 13

been two hotels that have sprung up along the 422 14

corridor with another one planned right up here at the 15

Sanatoga area. Again, more jobs and more economic 16

growth here for our communities. 17

Thirdly, I want to talk about the 18

communication that I've experienced in the seven years 19

that I've been in office with Exelon and with their 20

Government Affairs people as well as with their site 21

people. I've been on the site three times, twice for 22

a tour and one to make a presentation during an 23

anniversary of the facility. And I have to say that 24

it is a very secure area. I know a lot of people are 25


44

concerned about terrorism attacks or people being on 1

the property. But unless you've actually gone over 2

there and gone through a tour, seeing how things are 3

set up, seeing the armed guards there, seeing the 4

security measures that are in place, I think you come 5

away much more relieved with that. And I'm able to 6

speak to my constituents more affirmatively about the 7

safety and security of the facility. 8

Any time that there's been the slightest 9

occurrence there, whether it will be a couple times a 10

hunter has wandered onto the property where the 11

authorities were called, the Government Affairs people 12

at Exelon are on the phone to me or with an email 13

right away to let me know what's happening before the 14

word gets out to the media or to the press. So 15

they're always very well prepared in their 16

explanations, not only of things that happen at the 17

plant itself, but also incidents and issues that occur 18

around the country and around the world. 19

Obviously, what took place in Japan with 20

the incident over there, they were on the phone with 21

me and met with me a few times to explain what took 22

place over there and how the safeguards are being put 23

in place here so that doesn't happen at this facility. 24

It was mentioned earlier the dry cask 25


45

storage where the spent fuel rods are now stored 1

outside in a dry cask storage facility. When that was 2

proposed back in 2005-2006, the Generating Station 3

held two open houses that were very well attended. I 4

went to both of them where they had people on there to 5

explain to the people what exactly was taking place 6

with this dry cask storage, why it was necessary. A 7

lot of questions and answers back and forth and I 8

think a lot of the people came away better informed 9

about that process. 10

Just recently at an open house, the site 11

VP who just spoke, Bill Maguire, came out to give some 12

initial comments and wound up spending the full hour 13

in an impromptu question and answer session and not 14

again just planted questions, a lot of tough 15

questions. And I think again the people came away 16

feeling confident in the openness and the transparency 17

that was displayed in that question and answer 18

session. 19

Another point of that is for relicensing 20

for the overall environment here is the good corporate 21

citizenship that the Generating Station has exhibited. 22

As was mentioned by Bill, some of the charitable 23

contributions that have gone on, not only for the host 24

community of Limerick, but also for the surrounding 25


46

areas. I attended a few dedication services where 1

they provided money to the Upper Providence Elementary 2

School and the Limerick Elementary School for an 3

outside environmental classroom. 4

One of the things we talk about as 5

political leaders, and I'm on the House Education 6

Committee, is the need for our children to be educated 7

particularly in the sciences and given these budget 8

constraints that we're operating under, both the 9

school districts and the Commonwealth, it's good to 10

see a corporate citizen stepping up to the plate and 11

providing that financial support, particularly in the 12

area of science. They've also partnered with the 13

Montgomery County Community College to provide 14

assistance in support for an associate degree in 15

nuclear engineering technology. 16

Again, we hear so much about our students 17

here not being well versed in technology and 18

engineering and things of that nature. So again, 19

stepping up to the plate to provide that assistance 20

when, in fact, perhaps in these tough budget times 21

where the government might not be able to do that. 22

Last, I want to talk about overall public 23

opinion and safety issues. One of the things that I 24

looked at when I talk about safety and the feeling of 25


47

comfort that people have here is how many of the 1

people who work at that plant live within the ten-mile 2

radius of the facility? And I asked that question 3

when I first was elected in 2004 and I just asked it 4

again in preparation for this hearing and 563 5

employees live within the ten-mile radius. 6

The population growth in my District in 7

the past ten years, we're getting ready to redraw our 8

lines based on the 2010 Census, so I broke it down by 9

township as to how much the population has increased 10

in those areas: Limerick Township, increasing by 33.5 11

percent; Upper Pottsgrove by 29.5; Royersford Borough, 12

where I live, 11.9; Lower Pottsgrove, 7; Pottstown, 2; 13

now this is a little bit skewed, but I have a small 14

piece of New Hanover Township which actually increased 15

by 54 percent. 16

When you look at the public opinion, and 17

again, we get calls on a lot of different issues and 18

as I mentioned that dry cask storage issue. Back 19

then, at the same time that that issue was being 20

rolled out to the public, Boyd Gaming had purchased a 21

property next to our plant was getting ready to apply 22

-- had applied for a license, casino license. At that 23

time, my office had received 2 calls in regard to the 24

dry cask storage project, over 200 calls regarding the 25


48

casino application. So at the time, it appeared 1

people were more concerned about the prospect of a 2

casino being in their neighborhood than they were a 3

dry cask storage facility. 4

And lastly, as some of you heard, there is 5

a proposal right now to put a hold on Route 422. And 6

again, in the past six months with the incidents in 7

Japan, with the current earthquake we had here, with 8

the AP story telling you how these plants are all 9

falling apart, I received two calls regarding that one 10

where they could get the KI pills, one where they 11

could -- what was the evacuation plan for that, and 12

more calls and emails regarding the proposed 422. So 13

again, it appears that the constituents and the 146th, 14

they're more concerned about the prospect of paying a 15

toll to ride of 422 than they are about the nuclear 16

power plant issues. 17

So again, I strongly support the 18

relicensing of this for the reasons I mentioned. 19

Thank you. 20

(Applause.) 21

FACILITATOR BARKLEY: Thank you, 22

Representative Quigley. 23

The next three people I'd like to call, 24

first is Lorraine Ruppe, private citizen; and the 25


49

next, Michael Gallagher of Exelon; and finally, I'd 1

like to call Dr. Fred Winter after that. 2

MS. RUPPE: Hi, my name is Lorraine Ruppe. 3

I am speaking here today to represent the children 4

and future generations, especially in our community. 5

Residents are fearful about the possibility of 6

disasters here in light of Fukushima in March 2011 and 7

since the earthquake and Hurricane Irene in August 8

2011 affecting our area. Climate changes, etcetera, 9

are causing disasters everywhere and continuing to get 10

worse. 11

Increasing floods, droughts, earthquakes, 12

tornados have made us all feel insecure, making 13

nuclear power increasingly risky, especially with the 14

Limerick plant basically in our backyards. Any 15

earthquake that comes through this area could be a 16

possible Fukushima, Chernobyl or Three Mile Island 17

which reminds me, four months have passed since the 18

NRC failed to get back to me when I asked how close 19

the Remapo fault line is to the Limerick nuclear 20

reactors? Maybe I can get an answer today. 21

Indian Point nuke plant was sketched as a 22

possible terrorist target in reference to 9/11 23

attacks. A suspected terrorist worked at Limerick for 24

years without the industry knowing it. How scary is 25


50

that? 1

The Pacific Ocean is now severely 2

irradiated by Fukushima. Radiation impacts of 3

Fukushima equalled over 20 Hiroshima bombs when I last 4

researched. Our drinking and bathing water here is 5

being continuously polluted by Limerick every day, 6

24/7 for years with radiation and unfiltered toxic 7

contaminated mine water, thanks to the NRC and Exelon. 8

This is disgusting. 9

Most of us have to depend on the water, 10

especially for bathing. Some of us pay extra for 11

water filtration or drink bottled water because we are 12

afraid to drink from the Schuylkill and because it 13

tastes really bad now. Imagine how toxic it would be 14

18 plus years from now if there was even any water 15

left. 16

There has been increased particulate 17

matter in the air and other toxics from Limerick 18

causing increased asthma, heart attacks, and strokes. 19

And to add insult to injury, Limerick was granted a 20

permit to allow an eight-fold increase in air 21

pollution since 2009. Cancer rates in our area have 22

skyrocketed since Limerick has been up and running in 23

the '80s and rates have steadily increased. 24

The Toothfairy Project showed high levels 25


51

of strontium 90, a radionuclide in baby teeth of 1

children nearest to nuke plants. Baby teeth near 2

Limerick plant had the highest levels in the whole 3

United States. This stuff and God knows what else is 4

in our bodies now thanks to a Nuclear Regulatory 5

Commission that to put it nicely is less than 6

enthusiastic about protecting us. 7

Solar wind, geothermal, ocean thermal, 8

energy conservation and efficiency are now cheaper 9

than nuclear power, along with being truly clean and 10

safe. The Department of Energy 2006 report stated 11

solar alone could provide 55 times our entire nation's 12

energy needs which leads me to a point, there have 13

been numerous studies proving the many dangerous and 14

deadly consequences of nuclear power. There's no 15

denying the massive devastation it has already caused 16

and will continue to cause indefinitely, but the 17

industry still goes on in their trance-like, 18

indifferent fashion as if everything is safe and 19

wonderful and will continue to be 18 plus years from 20

now or until 2049 for our community. This is what 21

really scares us the most. 22

The NRC has turned into a culture of 23

secrecy, hiding the dangers and sweeping the problems 24

under the rug. The industry's addiction to money and 25


52

power has blinded them to moral life and death issues 1

and facts set right in front of their faces. But my 2

big question of the day is why is Exelon applying for 3

an extension 18 years ahead of time? Thank you. 4

(Applause.) 5

FACILITATOR BARKLEY: Thank you, Lorraine. 6

Mike? 7

MR. GALLAGHER: Good afternoon. My name 8

is Mike Gallagher and I'm the Vice President of 9

License Renewal for Exelon. I have overall 10

responsibility for the Limerick Generating Station 11

license renewal application. 12

Exelon has a great deal of experience with 13

license renewal, as we have already obtained the 14

renewed licenses for our Peach Bottom and our TMI 15

plants in Pennsylvania, our Oyster Creek plant in New 16

Jersey, and our Dresden and Quad Cities plants in 17

Illinois. 18

Just briefly about myself. I've been 19

working in the nuclear power industry for 30 years. I 20

was a licensed senior operator and plant manager at 21

Limerick and I worked at two other nuclear plants and 22

our corporate offices. 23

Mr. Maguire, the site vice president for 24

Limerick spoke about reasons for renewing the license 25


53

for Limerick. I'd like to speak briefly about the 1

process for preparing this license renewal application 2

and the amount of work and engineering analysis that 3

was put into preparing the application. 4

Because the license Generating Station can 5

be operated safely and reliably, Exelon decided to 6

pursue license renewal for Limerick. Limerick is a 7

very clean energy source which produces no greenhouse 8

gas emissions. Limerick is also good for the economy 9

in that it lowers market prices on electricity for the 10

citizens of Pennsylvania to the tune of $880 million 11

per year. 12

So in 2009, we announced our intention to 13

seek license renewal for Limerick. Later that year, 14

we started the work necessary to prepare the 15

application. After over two years of work, we 16

submitted the application to the Nuclear Regulatory 17

Commission on June 22, 2011. The application, as Lisa 18

had mentioned, when you print it out it's about 2100 19

pages. And when you put it in the binders it's three 20

large binders. It's a huge amount of information. 21

But that only represents a small part of the work that 22

was done for the engineering analysis to prepare this 23

application. 24

The total amount of engineering analysis, 25


54

if we printed it all out would be about 290 binders of 1

information. We invested over 60,000 manhours of 2

engineering work. Once we completed our engineering 3

work to prepare the application, we brought in experts 4

from outside Exelon to review the application to 5

ensure that it was complete, thorough and accurate. 6

Our total cost to prepare the application and get this 7

application reviewed by the NRC will be about $30 8

million. 9

There are two different parts of our 10

application, the safety review and the environmental 11

review. For the safety review, we took an in-depth 12

look at the history and the condition of the safety 13

equipment in the plant. We did that to determine 14

whether the necessary maintenance was being performed 15

on that equipment and to make sure that the equipment 16

will be able to operate when it's needed, not only for 17

today, but also for an additional 20 years of 18

operation. 19

When you look back at Limerick, when it 20

was built, all the equipment was new. It was 21

thoroughly tested to make sure it would perform 22

properly, but like anything else equipment does age. 23

That doesn't mean it won't work, but it does age and 24

certain activities need to be done to the equipment. 25


55

So we perform preventive maintenance. Sometimes we 1

refurbish the equipment. Some equipment is replaced. 2

There may be modifications done to upgrade the 3

equipment in the plant and in fact, as Bill Maguire 4

has stated, Limerick had spent over $200 million in 5

the last couple years alone to improve and modernize 6

the equipment and enhance plant operations and safety. 7

We also then reviewed calculations that 8

were performed as part of the original design of the 9

plant that were done to ensure that the plant could 10

operate safely for 40 years. We analyzed those 11

calculations and were able to confirm that the plant 12

would be able to operate safely for 60 years. 13

Overall, our conclusion from our engineering review 14

was that Limerick could operate safely for up to 60 15

years. 16

We also took a look at the environmental 17

impacts of continuing to operate Limerick. We looked 18

at all the impacts of continued impact of the plant on 19

the environment. Our conclusion is that impacts on 20

the environment are small and I use the term small in 21

the sense that is in the regulation. The regulation 22

defines small as environmental effects are not 23

detectable or are minor. 24

We also reviewed the alternatives if 25


56

Limerick would not have its license renewed and 1

another source of electric generation would need to be 2

installed either here on site or someplace else to 3

generate the replacement electricity. We concluded 4

that any other means of generating the replacement 5

electricity would have more of an impact on the 6

environment than continued operation of Limerick. For 7

instance, if Limerick could be replaced by a wind 8

generation facility, the wind form would have to 9

occupy between 10 and 40 percent of all the land in 10

the state of Delaware and that would have a huge 11

impact on the land. If a solar facility could replace 12

Limerick, it would need to cover 32 to 50 percent of 13

the entire land area of Montgomery County. 14

In conclusion, we operate Limerick safely 15

and we can continue to operate it safely for an 16

additional 20 years. Limerick will provide 17

approximately 2340 megawatts of base-load generation 18

that's not only safe, but it's clean, reliable and 19

economical. 20

Continued operation of Limerick will 21

benefit this community, the Commonwealth of 22

Pennsylvania and our nation. Thanks for giving me the 23

time for this. Thank you. 24

(Applause.) 25


57

FACILITATOR BARKLEY: Thank you, Mike. 1

Dr. Winter? 2

DR. WINTER: Good afternoon. Thanks for 3

letting me speak. We have heard a lot of pros and 4

cons, haven't we? And it's hard to make a decision 5

that's for sure. But let me get going here. 6

As a physician practicing radiology for 7

over 50 years, I still have strong concern about 8

cancer sensitivities from harmful radiation exposures, 9

naturally. My medical colleagues share the same 10

concerns because we have seen our cancer rates 11

increase since the Limerick power plant started, 12

especially thyroid cancer. It jumped to 78 percent 13

higher here than the national average. And some of 14

the people I talked to, this is because people are 15

aging more now, getting older, so there are more 16

cancers. But that's not true because in other areas 17

similar to our area in Pottstown, they're not nearly 18

getting the thyroid cancers that we are. This has 19

been well established by the state. 20

You wonder why some of our medical and 21

cancer fundraisers haven't reacted with more 22

responsibility in order to stop this. They're making 23

a lot of money, but not taking much effort to prevent 24

environmental damage. 25


58

Yes, we are creating our own form of 1

terrorism. Now that sounds kind of funny, doesn't it? 2

But allowing any harmful environmental events to 3

occur, we are allowing our own form of terrorism, just 4

like foreign people would come in here. 5

Having attended a Hiroshima, Japan atom 6

bomb clinic right after World War II, naturally I had 7

a chance to see the worst results of harmful 8

radiation. All those little kids I saw who only lived 9

for a few days, it left me with a very sad memory. Of 10

course, what is happening here will be taking much 11

longer, but it sure is not good. 12

I don't know whether you've heard that 13

some scientists are already predicting that -- I'm 14

sorry to tell you this, but nuclear energy has the 15

capacity of destroying mankind. It may take about 100 16

years, but our whole world is exposed to the harmful 17

effects, maybe not so much here in the United States, 18

but the whole world can be affected. 19

Of course, what is happening here will be 20

taking much longer, but it is sure not good news. 21

Besides harmful power plant exposures, we have 22

environmental disasters and a concern about our nearby 23

earthquake fault and others in the eastern U.S., 24

especially one near New York City. And then there are 25


59

the radioactive spent fuel deadly waste material 1

sitting around, supposedly protected. We can't 2

control the use of nuclear power in the rest of the 3

world, but can keep America safer and cleaner here. 4

So please, ask your politicians, reliable 5

politicians to close the Limerick power plant. Let's 6

save America for our kids and descendants. I hope you 7

will take my concerns seriously. And thank you for 8

listening. 9

(Applause.) 10

FACILITATOR BARKLEY: Okay, thank you, Dr. 11

Winter. The next three people I'd like to call is Tom 12

Neafcy of Limerick Township, followed by Dr. Anita 13

Baly, and then Tim Fenchel of the Schuylkill River 14

Heritage Foundation. 15

MR. NEAFCY: Good afternoon, thank you. 16

My name is Tom Neafcy. I'm the Chairman of Limerick 17

Township Board of Supervisors and I want to thank you 18

for this opportunity to speak at this forum today. 19

As the largest private employer in the 20

region, the Board is thankful for the 860 jobs that 21

Exelon provides, the positive impact of their 22

operation, the vitality of our local community. The 23

community and local economy are enhanced by the needed 24

services provided by the township, which includes the 25


60

roadway network maintained by our Limerick Township 1

Public Works, public safety provided by the Limerick 2

and Linfield Fire Companies, and our local emergency 3

medical response, our public parks, our recreation 4

facilities and also the police protection that's 5

provided by Limerick's 21 sworn officers. 6

Because of Limerick Generating Station's 7

location within our borders,the Limerick Township 8

Police Department is the only municipal police 9

department in Pennsylvania with the primary 10

jurisdiction over Tier 1 critical infrastructure. 11

This Board prides itself on the services provided 12

directly both to the residents and the businesses of 13

this community and the township's ability to maintain 14

those current levels of service during these difficult 15

economic downturns. We are thankful for the 16

generosity of the Limerick generating plant and Exelon 17

for being good corporate neighbors and the assistance 18

they provide to the community. Without their 19

financial assistance that impact to provide those 20

services to the community would fall squarely on the 21

backs of the taxpayers. They assist in our fire 22

companies. They have been corporate sponsors of our 23

Limerick Community Days. And we are confident that 24

Limerick generating facility and Exelon will continue 25


61

that support in the future and be our good corporate 1

neighbor. 2

We also are in support of the relicensing 3

of the Limerick nuclear plant. Thank you. 4

(Applause.) 5

FACILITATOR BARKLEY: Dr. Baly? 6

DR. BALY: Good afternoon. I'm Anita 7

Baly. I'm a retired Lutheran pastor and my concern 8

today is with the speed at which this application 9

process is going. I mean it seems to me that to 10

predict what environmental factors will be in place 13 11

years hence and 18 years hence, posits a kind of 12

omniscience and prescience that we should attribute to 13

Almighty God, but certainly not to any of us human 14

beings. 15

I would favor a slower process. As we 16

look around, we see that the population in this area 17

is getting denser all the time. The roads are not 18

being improved. And that leaves me with concerns 19

about how we would effect an evacuation were one 20

needed. I suspect strongly that we couldn't perform a 21

good evacuation today. And I also suspect that the 22

population will be increasing and the roads 23

deteriorating. In fact, just this morning in the 24

Pottstown Mercury, they were reporting on the hearing 25


62

that was held on Route 422 which is our main road 1

around here. And Barry Seymour is quoted, he's the 2

Executive Director of the Delaware River Valley 3

Regional Planning Commission, and he told last week's 4

forum audience that population projections anticipate 5

a 50 percent increase in the region and if we don't 6

increase capacity on 422, we will have virtual 7

gridlock all the way to the Berks County line. 8

Maybe we'll improve that situation, but 9

it's way too early to know if that will happen. And 10

so my plea and my concern is can we slow this down so 11

that we know, in fact, what the environmental impacts 12

are going to be closer to a time that the decision is 13

made. Thank you. 14

(Applause.) 15

FACILITATOR BARKLEY: Thank you. Tim? 16

MR. FENCHEL: Good afternoon. My name is 17

Tim Fenchel and I'm on the staff of the Schuylkill 18

River National and State Heritage Area. We are one of 19

49 congressionally-designated Heritage Areas in the 20

country and our mission is to use recreation, 21

conservation, education, cultural and historic 22

preservation and tourism as tools for community 23

revitalization and economic development with the 24

Schuylkill River Valley. 25


63

The Heritage Area has had the opportunity 1

for almost seven years now to partner with Exelon 2

Nuclear and the Limerick Generating Station on several 3

local and regional projects and programs. These 4

programs have proven to have a positive impact on our 5

local communities, residents, and natural resources. 6

And I would like to take a few moments to highlight 7

those now. 8

In 2005, Exelon Nuclear approached us 9

about the possibility of partnering together on a 10

grant program that would work to restore our area's 11

critical natural resource, the Schuylkill River. The 12

river has been detrimentally impacted by hundreds of 13

years of abuse and neglect, primarily as a result of 14

our nation's history related to the Industrial 15

Revolution. But even more recently, due to 16

deforestation, farming practices, and continued open 17

space development. 18

Beginning in 2006, after the creation of 19

grant program guidelines, an advisory committee and a 20

necessary accounting and reporting structures, Exelon 21

began making annual contributions to the Schuylkill 22

River Restoration Fund. The Schuylkill River Heritage 23

Area acts as the administrator and the manager of this 24

grant program, redistributing Exelon's contributions 25


64

to local and regional watershed groups, conservation 1

organizations, and local government agencies for 2

projects addressing the quality and quantity of 3

Schuylkill River water. Projects focusing on 4

agricultural remediation, abandoned mine drainage, and 5

stormwater runoff are supported through this program. 6

To date, Exelon has contributed over $1.2 7

million to the restoration fund for watershed-wide 8

projects. Twenty-two grants have been awarded and 11 9

projects have been completed. These projects have 10

made an impact on the water quality and quantity of 11

the Schuylkill River which is a source of drinking 12

water for over 1.75 million people in southeastern 13

Pennsylvania. 14

Exelon's establishment and contribution to 15

the restoration fund has been a model program and is 16

now a uniquely valued public/private partnership as 17

several new partners have joined efforts and made 18

their own contributions to the fund. Both the 19

Philadelphia Water Department and the Partnership for 20

the Delaware Estuary have brought funding to the 21

program and supported regional watershed projects. 22

The contributions made by Exelon have been the 23

catalyst to leverage additional funds well over 24

$600,000 for area restoration. 25


65

The goal of the Restoration Fund Advisory 1

Committee is to be able to support a sustainable level 2

of half a million dollars annually for the fund and in 3

turn, conservation projects that will continue to 4

ensure the future health of the Schuylkill River. 5

In addition to our work on the restoration 6

fund, we have assisted Exelon Nuclear, East Coventry 7

Township, and Chester County in a planning effort to 8

begin the process of restoration and preservation of 9

the historic Fricks Locks Village. Earlier this year, 10

Exelon Nuclear, the current owners of the village, 11

signed an agreement with East Coventry Township to 12

stabilize, rehabilitate, and protect several of 13

Chester County's oldest buildings. Exelon has agreed 14

to spend $2.5 million to restore the exterior of 15

several buildings as stabilized ruins. A fence will 16

be built around the grounds and the corporation is 17

donating four houses to the township worth an 18

estimated $1 million. 19

In addition, the corporation has agreed to 20

continue to do routine maintenance on the village and 21

work with the local historical society to host guided, 22

historic and educational tours for the public. 23

From our perspective, much of the success 24

of this partnership can be assigned to the hard work, 25


66

dedication and personal commitment of Exelon staff and 1

management. Based on the very positive community 2

programs and involvement we have experienced and 3

witnessed first hand as a regional organization, we 4

would like to communicate our support for the 5

relicensing and continued operation of Limerick 6

Generating Station. Thank you. 7

(Applause.) 8

FACILITATOR BARKLEY: Okay, thank you. 9

The next three people I would like to call, Bill 10

Vogel, followed by Eileen Dautrich, is that how you 11

say that? 12

MS. DAUTRICH: Dautrich. 13

FACILITATOR BARKLEY: Dautrich. Okay. 14

And then Bill Albany. 15

MR. VOGEL: Hi, my name is Bill Vogel. I 16

live in Phoenixville. Units 1 and 2 had an initial 17

life expectancy of 40 years. They are now asking to 18

increase that 20 years, a full one third increase. 19

Everything has a life expectancy, machinery, as well 20

as people. Demographically, my life expectancy is 74. 21

If I was to get a one third extension, like the 22

Limerick plant wants, that would take me to 111. What 23

do you think is going to happen to me between age 74, 24

my life span, my nameplate capacity, and the year when 25


67

I reach 111? It's going to go down hill. That's 1

lifecycle. Machinery has them. You don't need an 2

engineer to tell you that. Just like human beings 3

have them. We become less effective, less efficient, 4

less competent. 5

The significant difference is my failure 6

will be containable. Limerick's most likely will not. 7

If I drive over you with my car because I no longer 8

see as well or have the reflexes I once had, that's a 9

tragedy for you, your family, for me and my family. 10

The sphere of the tragedy is containable. If Limerick 11

Unit 1 or 2 fails, all hell breaks loose, no 12

disrespect. That's what a nuclear failure is, hell. 13

It affects everybody in this room, everybody in the 14

community, everybody in the tri-state area, not for a 15

week, but for decades. It's very, very last thing we 16

want to happen. 17

And I think we're putting ourselves in 18

harm's way by taking something that had a lifespan of 19

40 years and adding another 20 to it. It doesn't make 20

sense. The only way to rationalize it is through our 21

personal fear of being inconvenienced because we lose 22

a very, very good source of power. It's done a great 23

job for us. But like me, you get to a point where 24

your ability to provide a great job is at an end and 25


68

things start deteriorating. Let's not put ourselves 1

in that position. Let's make an intelligent decision 2

now and allow these two units to expire at their 3

nameplate time. Thank you. 4

(Applause.) 5

FACILITATOR BARKLEY: Thank you, Bill. 6

Eileen. 7

MS. DAUTRICH: Good afternoon. My name is 8

Eileen Dautrich. I'm president of the Tri-County Area 9

Chamber of Commerce. I'm happy to be here today to 10

provide examples of how Limerick Generating Station is 11

a valued community and business partner and echo the 12

statements already shared by several others. 13

They're one of the tri-county area's 14

largest employer, providing professional employment 15

opportunities for local residents. Those local 16

residents employed by Limerick Generating Station are 17

supporting the entire tri-county business community. 18

They're purchasing personal goods and services from 19

local small businesses. The annual outage is a 20

tremendous benefit to the local economy and our local 21

businesses. Limerick encourages their outage 22

employees to visit and purchase from tri-county area, 23

local businesses, and small businesses. 24

In addition to the jobs they provide local 25


69

residents, they're making a significant investment in 1

our local communities. Municipalities and residents 2

benefit from assistance received from Limerick to 3

start, maintain, expand parks, recreation, and quality 4

of life opportunities. 5

Their corporate culture of giving back to 6

the community is practiced by their hundreds of 7

employees. Nonprofit organizations are supported by 8

Limerick Generating Station and the efforts of their 9

employees. Financial donations, as well as volunteer 10

hours and time are donated, enabling our local 11

nonprofits to provide the much needed services that 12

impact those in need throughout the tri-county area. 13

The Limerick Generating Station is 14

confident in the clean and safe environment they 15

maintain in our community. The community has been 16

invited to experience the generating station 17

firsthand. The chamber hosted a membership breakfast 18

and the site vice president, Bill Maguire provided the 19

keynote presentation. He summarized safety measures 20

and advancements at Limerick and answered questions 21

pertaining to the Limerick plant and its safety in the 22

wake of the tsunami in Japan. 23

In addition, after our breakfast, Chamber 24

members were encouraged to attend the informational 25


70

meeting Limerick was holding for the community at 1

large, as well as participate in a tour of Limerick 2

Generating Station that was scheduled as a follow up 3

to our breakfast. 4

These opportunities for the community are 5

provided ongoing for the community to be informed and 6

educated about Limerick Generating Station. Thank 7

you. 8

(Applause.) 9

FACILITATOR BARKLEY: Bill? 10

MR. ALBANY: Good afternoon. My name is 11

Bill Albany. I'm the Chief of Police for Limerick 12

Township Police Department. As stated earlier the 13

Limerick Township Police Department is the only 14

municipal police department in the State of 15

Pennsylvania with primary law enforcement 16

responsibility for a nuclear power plant. 17

I am badged at the site and I am also a 18

co-chair of a subcommittee for the Joint Terrorist 19

Task Force Southeast Region. 20

I didn't want to talk too much about 21

environmental issues, but about my relationship with 22

LGS, particularly as it applies to their Security 23

Department, their Emergency Planning Department and 24

their management. In a lot of companies today, you 25


71

see policies and procedures that people talk about and 1

they're put up on a shelf and they're followed at best 2

haphazardly with a wink and a nod and deviation from 3

the policy is not addressed. 4

One of the things that I'm continuously 5

impressed at LGS when I visit is their sound adherence 6

to policy and procedure. They don't deviate from it. 7

I've been to numerous drills at the plant, numerous 8

exercises at the plant, some of which were run by the 9

NRC and I've never seen them fail. They always come 10

out on top. In fact, in 2009, Limerick was selected 11

as a site for the first comprehensive pilot exercise 12

involving federal, state, and local law enforcement 13

SWAT teams to actually go into the power block and 14

conduct tactical operations in there, and that drill 15

was used as a boiler plate to develop policies and 16

procedures for implementation in power plants 17

throughout the country. 18

One of the -- I'm sorry, I don't believe 19

that continued operations of the power plant would 20

have any detrimental effect on public safety in the 21

southeast region. Thank you. 22

(Applause.) 23


I'd like to call the final three speakers who have 25


72

signed up, John McGowan, Ted Del Gaizo, and Timothy 1

Phillips. John? 2

MR. McGOWAN: Thank you very much. My 3

name is John McGowan and I am a life-long resident of 4

the Delaware Valley. I have lived half of my -- or I 5

should say the Limerick Nuclear Power Station has been 6

operating for half of my life. I own three 7

manufacturing companies in the Malvern area and employ 8

a number of people in those facilities who rely 9

tremendously on the Limerick Power Generating Station 10

to supply safe, reliable electrical power to keep us 11

operating. 12

Today, I would like to say that in all of 13

the years that I've lived in this area, I've never 14

worried at all about the safety of the nuclear power 15

plant. I see it every day. And it bothers me not in 16

the least. I have never seen any credible evidence to 17

suggest that there are safety problems with this 18

plant. In terms of reliability, it is the same. It 19

is running 24/7, 365 days a year and it has been doing 20

so for a quarter of a century and I hope it continues 21

to do so for many more years to come. 22

As far as its environmental impact, I 23

think it's pretty widely known that nuclear power is 24

one of the cleanest environmental energies that we 25


73

possess today throughout the world and to dismiss it 1

is I think a foolish notion. 2

The impact of the Limerick plant in our 3

region has been extraordinarily positive. It 4

provides, as we all know and have heard today, lots of 5

jobs, lots of good jobs, tax revenues for schools, 6

local governments and for those who live in the area 7

to enjoy the fruits of public services and it also 8

provides a lot of charitable donations to the 9

community which is very important. 10

I think that to not keep this plant 11

running and not consider a renewal of its license for 12

an extended period would be a tragic mistake for all 13

of us and I would like to end this by saying that the 14

only meltdown that would concern me is the economic 15

one that certainly would happen to this area should 16

this plant not continue to operate. 17

(Applause.) 18

FACILITATOR BARKLEY: Ted, go ahead. 19

MR. DEL GAIZO: Hi, my name is Ted Del 20

Gaizo. I'm a registered professional engineer in the 21

Commonwealth of Pennsylvania. I'm also president and 22

CEO of a small business engineering firm in nearby 23

Exton, Pennsylvania. 24

My experience in nuclear power goes back 25


74

to the 1960s where I spent 14 years in Navy submarines 1

and I personally operated, maintained, and refueled 2

nuclear power plants during that period. 3

But I'm here today as a private citizen, 4

as a resident of the area and as a member of the 5

Pennsylvania Energy Alliance to go on record and say I 6

strongly favor license renewal for the Limerick 7

Generating Station. I say that because in my personal 8

experience I know in spite of some of the things 9

you've probably heard here today, nuclear power is 10

safe, reliable, secure and clean. But in addition to 11

that, I would like to go on record, I would like my 12

neighbors to know we are lucky to have the Limerick 13

Generating Station in this area. In the industry, it 14

has a top reputation. It is one of the finest nuclear 15

power plants in America. And Exelon, if not the best, 16

is certainly one of the finest nuclear operators in 17

the world. 18

I have nothing but confidence that Exelon 19

will work together with the NRC, will run through the 20

process and we will come up with the right conclusion 21

here which is license renewal should be granted to the 22

Limerick Generating Station. I think we need to keep 23

Limerick operating as long as we can. 24

In addition, in spite of some other things 25


75

you may have heard here today, I'd like to thank the 1

NRC for the fine job they do on protecting the health 2

and safety of the public. I think as a regulatory 3

agency you're one of the finest in the world. 4

Certainly, the world follows everything you do. And 5

I'm sure you'll come up with the right conclusion here 6

and thank you for what you do for the United States. 7

(Applause.) 8

FACILITATOR BARKLEY: Timothy? 9

MR. PHELPS: Good afternoon. My name is 10

Tim Phelps. I'm the former president of the Tri-11

County Area Chamber of Commerce, but I'm here as a 12

citizen, not a citizen of the Limerick community, but 13

a citizen of East Whiteland. After I left the 14

Chamber, I still stayed involved in the Exelon 15

Generating Station through their CAP program. I 16

thought was extremely important because of the 17

information that was provided to the community through 18

the CAP. And I'm able to share this information, 19

share the benefits and share what's happening here at 20

the nuclear power plant. 21

I have to thank the NRC for actually 22

hosting -- this is a part of their process of making 23

the transparency available to everybody, for the press 24

to be here in the room. That shows that there's an 25


76

openness in the thinking process that goes into place 1

for renewal of any nuclear power plant. 2

And so from my perspective as a citizen, 3

as a business person who has worked in this community, 4

I understand the value this is to the region. And for 5

me, I applaud the NRC for what they're doing here. I 6

applaud Exelon for the great work that they're doing 7

there and I encourage the renewal process to take 8

place. Thank you. 9

(Applause.) 10

FACILITATOR BARKLEY: Thank you. With 11

that, I have all 15 people who had signed up for this 12

meeting, have been called. Is there anyone else who 13

would like to make a short follow-up remark or would 14

like to still speak at this point? 15

Okay, if not, I'd like to make two points 16

before we wrap up. One, the NRC does have public 17

meeting feedback forms which give us feedback on how 18

you think this meeting was conducted, so I would 19

greatly appreciate you filling out one of those forms 20

for us so that we can learn how to improve. There is 21

another session of this meeting at 7 o'clock tonight. 22

You're welcome to speak again tonight. 23

And secondly, what I'd like to say is I 24

facilitate a lot of meetings throughout the Northeast 25


77

and I find groups have very differing opinions on both 1

sides of this issue and often are not respectful or 2

civil towards each other. I thought the audience this 3

evening was marvelous and exemplary towards each other 4

and I greatly appreciate that. I did not have to 5

interrupt or intervene, so I very much thank you for 6

that. 7

With that, I'd like to wrap up this 8

meeting and the NRC will still stay around to answer 9

questions and please talk with them some more. Thank 10

you very much. 11

(Applause.) 12

(Whereupon, at 3:45 p.m., the public 13

meeting was concluded.) 14

15

16

17

18

19

20

21

22

23

24

25

Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION Title: Limerick Generating Station License Renewal Public Meeting: Evening Session Docket Number: (n/a) Location: Pottstown, Pennsylvania Date: Thursday, September 22, 2011 Work Order No.: NRC-1128 Pages 1-87 NEAL R. GROSS AND CO., INC. Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433


1

UNITED STATES OF AMERICA 1

+ + + + + 2

NUCLEAR REGULATORY COMMISSION 3

+ + + + + 4

PUBLIC MEETING TO DISCUSS THE LICENSE RENEWAL 5

PROCESS AND ENVIRONMENTAL SCOPING FOR LIMERICK 6

GENERATING STATION, UNITS 1 & 2 7

+ + + + + 8

THURSDAY 9

SEPTEMBER 22, 2011 10

+ + + + + 11

The Public Meeting met in the Sunnybrook 12

Ballroom, 50 Sunnybrook Road, Pottstown, Pennsylvania, 13

at 7:00 p.m., Richard Barkley, Meeting Facilitator, 14

presiding. 15

PRESENT 16

RICHARD BARKLEY, Meeting Facilitator, NRC 17

ROBERT F. KUNTZ, Project Manager, NRR/DLR 18

DENNIS C. MOREY, Branch Chief, NRR/DLR 19

LISA M. REGNER, Sr. Project Manager, 20

NRR/DLR 21

DAVID J. WRONA, Branch Chief, NRR/DLR 22

23

PUBLIC COMMENTERS 24

CATHERINE ALLISON 25


2

JIM BECKERMAN 1

JEFF CHUMNUK, Pottstown Borough Council 2

TRACI CONFER, Energy Justice Network 3

DONNA CUTHBERT, Alliance For a Clean 4

Environment 5

LEWIS CUTHBERT, Alliance For a Clean 6

Environment, PhD 7

JIM DERR 8

DAN ELY 9

MICHAEL GALLAGHER, Exelon Nuclear 10

DANIEL LUDEWIG 11

JEFFREY G. NORTON, Pennsylvania Energy 12

Alliance 13

WILLIAM MAGUIRE, Exelon Nuclear 14

LORRAINE RUPPE 15

THOMAS SAPORITO, Saprodani Associates 16

FRED WINTER, MD 17

18

19

20

21

22

23

P-R-O-C-E-E-D-I-N-G-S 24

7:01 p.m. 25


3

FACILITATOR BARKLEY: Good evening. Could 1

everyone take a seat so we can start the meeting? 2

It's actually about two minutes after 7:00. Okay, 3

good evening. For those of you who were not at the 4

afternoon meeting my name is Richard Barkley. I'm the 5

meeting facilitator for this meeting. We had a very 6

successful meeting this afternoon, 15 individuals 7

spoke and the meeting went very, very smoothly. 8

Hopefully that's the same situation this evening. If 9

you are interested in speaking hopefully you've signed 10

up. If not there is a sign-up sheet at the back or 11

you can see me and we'll work with signing you up. 12

I wanted to go briefly over some of the 13

ground rules for this meeting as we go through it. It 14

worked very well again this afternoon and hopefully it 15

will be fine this evening. First of all, one of them, 16

we ask you to sign up on a yellow speaker card and I 17

have that for individuals, or on a white piece of 18

paper that we had back there in the back. At this 19

point I have 12 people signed up. We had 15 this 20

afternoon but I'll probably pick up two or three as 21

this meeting goes on. To be fair the amount of time 22

allotted will be limited based on the number of 23

speakers who speak up or who ask to sign up. This 24

afternoon we went through 15 speakers in 75 minutes. 25


4

It works out to about five minutes a person. Some of 1

them had a little variation but that seemed to be 2

adequate to present your remarks in a concise manner. 3

I typically call three people at a time so 4

the first person comes up, the other two people know 5

they're going to be called shortly thereafter. That 6

makes for a smooth transition from one speaker to the 7

next. And we do have one or two members of elected 8

officials here who have signed up and so I'll call 9

some of them and alternate between them and individual 10

members of the public. 11

At this point in time I believe there was 12

one representative of an elected representative in the 13

audience. Would any members who are elected officials 14

want to speak up? That was represented. Yes, sir. 15

MALE PARTICIPANT: I'm representing 16

Senator Casey. 17


Anyone else? Yes, sir. Let's go on to the next slide 19

here. Yes, sure. 20

MS. ALLISON: I wondered if earlier today 21

you said you had 15 people speak. 22

FACILITATOR BARKLEY: I had 15 people 23

speak, yes. 24

MS. ALLISON: Now how many are allowed to 25


5

speak at this meeting? 1

FACILITATOR BARKLEY: Right now I have 11 2

signed up but if more want to sign up it's fine. If 3

we work smoothly there's 15. I'm hoping this evening 4

we'll have roughly 15. Many of the same speakers that 5

spoke this afternoon will speak this evening. 6

MS. ALLISON: Okay. One other question. 7

I would like to know why sometimes according to this 8

we get five minutes and I know there are people who 9

have to speak but it's hard to say something so 10

important in five minutes. Something that -- it's 11

just -- 12

(Applause) 13

FACILITATOR BARKLEY: And again, I 14

understand your point. There were several speakers 15

that actually went seven to eight minutes who I gave 16

latitude. If you have much longer comments this is 17

only one format to handle these comments. You can 18

also supply them in a written form. We have some 19

flexibility, I will give you flexibility but just to 20

follow the time that's -- go ahead. 21

MS. ALLISON: How many meetings do we have 22

like this to speak? How many opportunities do we have 23

to speak? That we have like this. 24

FACILITATOR BARKLEY: Meetings with the 25


6

license-holder or just this facility? 1

MS. ALLISON: Where the public is allowed 2

to speak. 3

FACILITATOR BARKLEY: We have public 4

meetings on a very frequent basis but regarding 5

Limerick this is the first one related to license 6

renewal. But we have many, many comments that are 7

received in a written format versus in a verbal 8

format. 9

MS. ALLISON: Well, I'd like to know how 10

many opportunities the public gets to speak and why we 11

get five minutes. 12

FACILITATOR BARKLEY: Continuing on I 13

would ask you to silence your cell phones so we don't 14

have interruption. Yes, sir, I'm sorry. 15

MR. TROUT: If people who speak from the 16

floor could use their microphones then we could all 17

hear what you have to say. 18

FACILITATOR BARKLEY: Okay, understood. 19

The gentleman had difficulty hearing the question. 20

But I can summarize that. I'll talk to you privately 21

about that. Again, if we could speak clearly into the 22

microphone. This afternoon we had the microphone 23

facing backwards. You weren't facing the audience. 24

This time we're going to try to have it facing the 25


7

audience. That seems to be a little bit more 1

desirable for speakers. Again, written comments are 2

welcome during and after this meeting. At some of our 3

licensees we have had many, many times as many written 4

comments provided regarding the Environmental Impact 5

Statement as we have in verbal comments. Some of our 6

stations, I think Indian Point had almost 2,000 7

comments submitted, only about 50 of them in a verbal 8

format in a meeting such as this. And then again if 9

there are questions or concerns regarding the conduct 10

of this meeting please see me and we'll work through 11

them. All right? Go ahead, Rob. I'd like to turn it 12

over to Rob Kuntz now, please. 13

MR. KUNTZ: Good evening. My name is Rob 14

Kuntz. I'm the Safety PM for the -- in charge of the 15

review for the Limerick Generating Station License 16

Renewal Application. I'd like to thank you all for 17

taking the time and attending the meeting this 18

evening. Tonight we will provide an overview of the 19

license renewal review process which includes both a 20

safety review and an environmental review. We will 21

describe to you the numerous ways and opportunities 22

the public can participate in the Limerick license 23

renewal process through either the safety or the 24

environmental renewal review. But the most important 25


8

part of today's meeting is to receive any comments 1

that you may have on the scope of the environmental 2

review. We also will give you some information about 3

how you can submit comments if you prefer not to speak 4

at this meeting. 5

At the conclusion of today's -- tonight's 6

presentation we'll be happy to answer any questions 7

that you may have on the license renewal process. 8

However, I must ask you to limit your participation to 9

questions only and hold the comments until the 10

appropriate portion of the meeting. Once all 11

questions are answered we can begin to receive any 12

comments that you have on the scope of the 13

environmental review. Next slide. 14

Before I get into discussion of the 15

license renewal process I'd like to take a minute to 16

talk about the NRC in terms of what we do and what our 17

mission is. The NRC is a federal agency established 18

by the Energy Reorganization Act of 1974. We regulate 19

the civilian use of nuclear material. The Atomic 20

Energy Act of 1954 authorizes the NRC to grant a 40-21

year operating license for nuclear power reactors. 22

The 40-year term was based primarily on economic and 23

antitrust factors, not on safety or technical 24

limitations. The Atomic Energy Act also allows for 25


9

license renewal. The National Environmental Policy 1

Act of 1969, also referred to as NEPA, established a 2

national policy for considering the impact of federal 3

decision-making on the human environment. Lisa will 4

discuss NEPA in greater detail. 5

The NRC's regulations governing nuclear 6

safety, security and environmental protection are 7

contained in Title 10 of the Code of Federal 8

Regulations, often referred to as 10 CFR. In 9

exercising its regulatory authority the NRC's mission 10

is threefold: to ensure adequate protection of public 11

health and safety, to promote the common defense and 12

security, and to protect the environment. The NRC 13

accomplishes its mission through a combination of 14

regulatory programs and processes such as establishing 15

rules and regulations, conducting inspections, issuing 16

enforcement actions, assessing licensee performance 17

and evaluating operating experience from nuclear 18

plants across the country and internationally. The 19

NRC has resident inspectors at all operating nuclear 20

power plants. These inspectors are considered the 21

eyes and ears of the NRC. They carry out our safety 22

mission on a daily basis and are on the front lines of 23

ensuring acceptable safety performance and compliance 24

with regulatory requirements. Next slide. 25


10

A little bit about the Limerick license 1

renewal. That application was received on June 22nd 2

of this year. The operating license is expiring in 3

2024 for Unit 1 and 2029 for Unit 2. A license can be 4

-- a licensee can submit an application up to 20 years 5

prior to the expiration of their license. The length 6

of the license cannot exceed 40 years and the renewed 7

license supercedes the previous license. Next slide. 8

The first step of the license renewal 9

process is to perform an acceptance and sufficiency 10

review of the application. When the NRC receives a 11

license renewal application the NRC staff examines it 12

to determine whether the application contains 13

sufficient information to justify the staff's review. 14

The staff looks to see whether the applicant has 15

provided enough information in terms of technical 16

information, technical specifications and the 17

environmental report so that the staff can begin its 18

work. If the application has enough in it to warrant 19

the staff's review then the application is considered 20

acceptable and sufficient and is put on the NRC's 21

docket. General information such as the applicant's 22

name and address, business and administrative 23

information, technical information about the plant 24

structures and components and how the applicant 25


11

proposes to manage aging, pertaining to aging 1

management. This information is the focus of the 2

staff's safety review. 3

Technical specifications define the 4

operating parameters of the plant. The application 5

indicates what, if any, changes or additions to 6

technical specifications are necessary to manage the 7

effects of aging during the period of extended 8

operation. The application also includes an 9

environmental report which is the applicant's 10

assessment of the environmental impacts of continued 11

operation. This information is the starting point for 12

the staff's environmental review which will be 13

discussed a bit later in this presentation. Next 14

slide. 15

I'd like to mention a few very important 16

areas of NRC oversight that routinely come up during 17

our interactions with the public. NRC staff address 18

these areas of performance every day as part of the 19

ongoing regulatory oversight provided for all 20

currently operating power reactors. They include 21

current safety performance as defined by NRC 22

inspection findings, violations and general assessment 23

of plant performance, emergency planning and security. 24

For specific information on the current performance 25


12

at Limerick you can use the link that's provided on 1

the slide here. The NRC monitors and provides 2

regulatory oversight of activity in these areas on an 3

ongoing basis under the current operating license. 4

Thus, we do not reevaluate them in license renewal. 5

That's not to say they're not important, we just don't 6

duplicate the regulatory process in these areas for 7

license renewal. Next slide. 8

I'd like to talk briefly about the NRC's 9

response to the incident in Japan. Since the accident 10

at Fukushima the NRC has taken multiple steps to 11

ensure the safe operation of nuclear power plants both 12

now and in the future. As part of its initial 13

response to the accident the NRC issued temporary 14

instructions to inspectors directing specific 15

inspections of nuclear power plants in order to assess 16

disaster readiness and compliance with current 17

regulations. The next step in the NRC's response was 18

the report of NRC's Near-Term Task Force. The purpose 19

of the Near-Term Task Force was to develop near-term 20

recommendations and suggest a framework for us to move 21

forward in the long term. The Near-Term Task Force 22

issued its report on July 12th and discussed the 23

results of their review in a public meeting held on 24

July 28th. As a result of its review the Near-Term 25


13

Task Force presented 12 overarching recommendations 1

for improvement. These recommendations are applicable 2

to operating reactors regardless of license renewal 3

status. 4

Based on the results of the Near-Term Task 5

Force the Commission has directed the NRC staff to 6

evaluate and outline which of the recommendations 7

should be implemented. The staff submitted a paper to 8

the Commission on September 9th providing the staff's 9

recommendation on which task force recommendations can 10

and in the staff's judgment should be initiated in 11

part or in whole without delay. On October 3rd the 12

staff will submit another Commission paper on its 13

prioritization of 11 of the 12 task force 14

recommendations. Recommendation 1 of the task force, 15

the recommendation to reevaluate the NRC's framework, 16

will be evaluated over the next 18 months. To date 17

the NRC has not identified any issues as part of these 18

activities that call into question the safety of any 19

nuclear facilities. Additionally, this review process 20

is going on independent of license renewal. Any 21

changes that are identified as necessary will be 22

implemented for all licensees regardless of license 23

renewal status. 24

More information on the NRC's post-25


14

Fukushima activities including the results of the 1

Near-Term Task Force can be found on NRC's website by 2

clicking on the Japan Nuclear Accident NRC Action link 3

on the home page, or directly through the web address 4

on the slide. There are also a limited number of 5

copies of the Near-Term Task Force Report that are 6

available in the back of the room. 7

Now on to the license renewal process. 8

Here's a simplified diagram of the license renewal 9

process. License renewal review involves two parallel 10

paths, the safety review and the environmental review. 11

These two reviews evaluate separate aspects of the 12

license renewal application. It also features three 13

other considerations in the Commission's decision of 14

whether or not to renew the license. One of these 15

considerations is the independent review performed by 16

the Advisory Committee on Reactor Safeguards, also 17

known as the ACRS. Statutorily mandated by the Atomic 18

Energy Act of 1954 the ACRS is a group of scientists 19

and nuclear safety experts who serve as a consulting 20

body to the Commission. The ACRS reviews license 21

renewal application, the NRC staff's safety 22

evaluation, and inspection of findings. The ACRS 23

reports their findings and recommendations directly to 24

the Commission. 25


15

Hearings may also be conducted if 1

interested stakeholders submit concerns or contentions 2

and their request for hearing is granted. The Atomic 3

Safety and Licensing Board, an adjudicatory panel, 4

will conduct the hearing. The Commission considers 5

the outcome of the hearing process in its decision on 6

whether or not to renew the license. 7

As part of the environmental review, the 8

staff consults with local, state, federal and tribal 9

officials such as the EPA and the staff holds public 10

meetings to receive comments on the draft EIS, 11

Environmental Impact Statement. Next slide. 12

To better understand the license renewal 13

process it is good to know the safety principles that 14

guide license renewal. The first principle is that 15

current regulatory process is adequate to ensure the 16

licensing basis of all operating reactors provides or 17

maintains an acceptable level of safety. A second 18

principle is that the current plant's specific 19

licensing basis must be maintained during the renewal 20

term in the same manner and to the same extent as 21

during the original term. In other words, the same 22

rules that apply under the current license will apply 23

in the renewal term. In addition, a renewed license 24

will include conditions that must be met to ensure 25


16

aging of structures and components important to safety 1

is adequately managed so that the plant's current 2

licensing basis is maintained during the period of 3

extended operation. Next slide. 4

Safety review focuses on the aging of 5

passive and long-lived structures and components and 6

systems that the NRC has deemed important to safety. 7

Components within the scope of license renewal are 8

defined in 10 CFR 54.4 and include safety-related 9

systems, structures and components, non-safety related 10

systems, structures and components whose failure could 11

prevent satisfactory accomplishment of safety-related 12

functions, and structure systems and components relied 13

on in safety analysis or plant evaluations to perform 14

a function that demonstrates compliance with 15

regulations for fire protection, environmental 16

qualification, pressurized thermal shock, anticipated 17

transient without scram and station blackout. Passive 18

components are components who perform function without 19

moving parts or change in configuration or properties. 20

Active components are generally excluded from the 21

scope of license renewal. Degradation is more readily 22

detected by existing surveillance and performance 23

condition monitoring for these active components. 24

The staff's main objective in this review 25


17

is to determine if the effects of aging will be 1

adequately managed by the applicant. The results of 2

the staff's review are documented in the Safety 3

Evaluation Report. Next slide. 4

The safety review comprises numerous 5

aspects. The technical staff reviews the application 6

and supporting documentation to determine the 7

applicant's methodology for identifying systems, 8

structures and components within the scope of license 9

renewal and subject to an aging management review. 10

Also determined if the methodology has been properly 11

implemented and to determine with reasonable assurance 12

that the effects of aging for certain systems, 13

structures and components will be adequately managed 14

or monitored by new and existing programs and 15

surveillance activities. The staff uses site visits 16

called audits to verify the technical basis of the 17

license renewal application and to confirm that the 18

applicant's aging management programs and activities 19

conform with how they are described in the license 20

renewal application. The staff documents the basis 21

and conclusion of its review in a Safety Evaluation 22

Report which is publicly available. In addition, a 23

team of specialized inspectors travel to the reactor 24

site to verify the aging management programs are being 25


18

implemented, modified or planned consistent with the 1

license renewal application. Finally, as I've 2

mentioned, the ACRS performs an independent review of 3

the license renewal application, the staff's SER and 4

inspection findings and makes a recommendation to the 5

Commission regarding the proposed action to issue a 6

renewed license. Next slide. 7

The next slide shows some milestones for 8

the review of the Limerick license renewal 9

application. As you can see today, September 22nd, 10

the Environmental Scoping Meeting. October 24th, the 11

opportunity to file hearing closes, and there's some 12

other dates as we progress through. And these are 13

pending any unforeseen circumstances related to the 14

review. All right, that concludes my portion of the 15

presentation. I'll turn it over to Lisa Regner. 16

MS. REGNER: Good evening. Thank you, 17

Rob. Good evening, thank you for coming out tonight. 18

I know it's hard to take a night out and listen to 19

government officials but we do want to keep you 20

informed of our process. My name's Lisa Regner. I'm 21

going to talk about the environmental review during 22

the Limerick license renewal review. I'd like to 23

explain to you briefly about this separate but equally 24

important review. 25


19

This review is performed in accordance 1

with the National Environmental Policy Act of 1969, or 2

NEPA, as Rob mentioned already. NEPA established a 3

national policy for conducting -- considering 4

environmental impacts and provides the basic 5

architecture for federal environmental reviews. All 6

federal agencies must follow a systematic approach in 7

evaluating potential impacts for projects, for federal 8

projects, and also to assess alternatives to those 9

actions. By law the NEPA process involves public 10

participation and public disclosure. 11

NEPA established the U.S. Council on 12

Environmental Quality within the Executive Office of 13

the President and the Council on Environmental Quality 14

establishes policy for implementation of NEPA. The 15

NRC's environmental regulations contained in 10 CFR 16

Part 51 are largely based on those that CEQ developed. 17

Our environmental reviews consider the 18

impact of license renewal and any mitigation for those 19

impacts that we consider to be significant. We also 20

consider the impacts of alternatives to the license 21

renewal, including the impacts of not renewing the 22

license. The staff documents its environmental review 23

in an Environmental Impact Statement which is made 24

publicly available. Ultimately the purpose of the 25


20

staff's environmental review is to determine whether 1

the environmental impacts of license renewal are 2

reasonable and in combination with the other reviews 3

that Rob mentioned, the safety, inspection and ACRS, 4

Advisory Committee for Reactor Safeguards review, we 5

take that information and make a recommendation to the 6

Commission whether to renew the license or not. Next 7

slide. 8

During the review, the NRC environmental 9

staff looks at a wide range of impacts. Additionally 10

we consult with -- and the impacts are listed up here 11

on this slide. We also consult with various federal, 12

state and local officials as well as leaders of Indian 13

nations. We gather pertinent information from these 14

sources and ensure it's considered in our analysis. 15

So some of the agencies that we consult with are U.S. 16

Fish and Wildlife Service, the Environmental 17

Protection Agency, the Pennsylvania Department of 18

Conservation and Natural Resources, the State Historic 19

Preservation Office, and again, displaced tribal 20

nations. Next slide. 21

The environmental review begins with a 22

scoping process which is an assessment of the specific 23

impacts and significant issues that the staff should 24

consider in preparing the Limerick Environmental 25


21

Impact Statement. Currently this is where we are in 1

the process and it's an important part of this meeting 2

as well. Information we gather from you today and in 3

the next few weeks will be considered and included in 4

the Environmental Impact Statement. We recognize that 5

some impacts are similar if not identical at all 6

plants so to improve efficiency the staff developed 7

what we call a Generic Environmental Impact Statement 8

and that addresses a number of impacts common to all 9

nuclear power plants. 10

So we then supplement that generic EIS 11

with a Site-Specific Environmental Impact Statement in 12

which we address issues that are specific to the 13

Limerick site. In addition, we also reexamine the 14

conclusions reached in the Generic Environmental 15

Impact Statement to determine if there's any new and 16

significant information that would change the 17

conclusions in the GEIS. Next page, please. 18

The scoping period started on October 26th 19

of this year when the Notice of Intent to Prepare an 20

EIS and Conduct Scoping was published in the Federal 21

Register. The NRC will accept comments from you, from 22

the public on the scope of the environmental review 23

until October 28th, 2011, this year. In general what 24

we're looking for is information about environmental 25


22

impacts from the continued operation of Limerick. You 1

can assist us in that process by telling us for 2

example what aspects of your local community we should 3

focus on, what local environmental, social and 4

economic issues the NRC should examine during our 5

environmental review, what other major projects are in 6

progress or planned in the area, and what reasonable 7

alternatives are most appropriate for this region. 8

These are just some of the examples of the input we're 9

looking for and they represent the kinds of 10

information that we seek through the environmental 11

scoping process. We don't know your community like 12

you do, we at headquarters, so your comments tonight 13

provide insight and ensure a thorough review. Next 14

slide. 15

So this kind of gives you an overview of 16

what goes into our decision. Public comments are an 17

important part of the environmental review process. 18

So how do we use your comments? All of your comments 19

to us, whether provided verbally during this meeting 20

or in a written letter, fax, email, delivered 21

personally to the NRC, as long as they're written they 22

are accepted and they are considered. We respond to 23

each comment as part of the Supplemental or plant-24

specific Environmental Impact Statement. The 25


23

Supplemental Environmental Impact Statement is one of 1

the factors as well as -he several other factors shown 2

here that influences the Commission's decision to 3

renew the license or not. Next slide. 4

In addition to providing verbal and 5

written comments at this meeting there are several 6

other ways that you can submit comments for our review 7

process, and there's no limit to the length of those 8

written comments. You can submit comments online 9

using the federal rulemaking website which is 10

regulations.gov. And up at the top of that website 11

you'll see a box where you can enter a keyword or ID. 12

If you type in the NRC-2011-0166 docket ID then it 13

will list, it should list up at the top Exelon 14

Generation Company Notice of Intent to Prepare an 15

Environmental Impact Statement and Conduct Scoping 16

Process for Limerick. Okay. And then on the right 17

side of the screen you'll see a link to submit a 18

comment. Okay, so that's one way at regulations.gov. 19

You can also fax your comments to the number here. 20

And it might be easier if you reference Limerick or 21

put the docket ID number when you fax your comments. 22

That way we know it's for Limerick. Okay, next slide. 23

You can also submit comments by mail to this website 24

or you can come, if you happen to be in Rockville near 25


24

D.C. you can come to headquarters, NRC headquarters, 1

and submit written comments. And you're welcome to 2

give me a call and I can help you with that. 3

Actually, and you can, if you have any problems with 4

any of these submittal methods feel free to give me a 5

call and I can help you through that process. Okay? 6

And I did want to remind people that comments, we'd 7

like to have comments submitted by October 28th, 8

please. Next slide. 9

So here are environmental review 10

milestones. These are a little more specific to the 11

environmental review but I did list the hearing 12

opportunity because those are two dates that are 13

coming up. And this is not the only time that we will 14

have a public meeting. These two public meetings that 15

we have on scoping today are, one of the two major 16

public meetings that we will have, the next one will 17

be once the staff has prepared a draft Supplemental 18

Environmental Impact Statement for Limerick. We will 19

issue that publicly and then again we welcome public 20

comments on that draft SEIS. And right now that's 21

tentatively scheduled for either late August or early 22

September 2012, so next summer, early fall. Okay. 23

And again, we will have two meetings. Next slide. 24

So this is our contact information. Rob 25


25

and I are the primary points of contact within the NRC 1

for license renewal issues for Limerick. Okay. 2

Again, Rob is safety and I am environmental. Next 3

slide, please. Now, if you don't have a computer and 4

would like to view the license renewal application 5

there are -- we've placed hard copies at the two 6

libraries listed here. Pottstown Regional Public 7

Library and Royersford Free Public Library both have 8

the application available in hard copy. Also if you 9

do have a computer and want your own personal copy I 10

do have some disks in the back and you're welcome to 11

take those. The draft SEIS will also be available at 12

these libraries when it's published for comment. 13

They'll also be on the NRC website at the address 14

shown here on the slide. As you came in you were 15

asked to fill out a registration card at our reception 16

table. If you include your email address we'll sign 17

you up for the Limerick listserv which will provide 18

any NRC documents associated with Limerick, but if you 19

put your address on the card we will send you a hard 20

copy of the Environmental Impact Statement. This 21

concludes my presentation. I'd like to open the floor 22

up for questions. 23

FACILITATOR BARKLEY: Before we move to 24

the public comment period were there any questions 25


26

regarding this presentation? Yes, sir. 1

MALE PARTICIPANT: Did you say in the back 2

of the room there's a disk -- there are disks with the 3

licensee application and submission? What's that? 4

FACILITATOR BARKLEY: Yes, so we'll be 5

glad to give you a copy of that. The entire 6

application is on that disk. With that I'd like to 7

move to our -- sorry. Yes, sir. 8

MALE PARTICIPANT: Are copies of these 9

slides available? 10

MS. REGNER: They will be, yes. Copies of 11

the slides will be available in our agency-wide 12

document management system. And I can either give you 13

that number, if you want to see me after the 14

presentation I can give you that number or you can 15

email me and I'd be happy to send you a copy. 16

FACILITATOR BARKLEY: Is there another 17

question? Okay. With that what I'd like to do is 18

call the first speaker. 19

MS. REGNER: Are we going to do Mr. 20

Saporito? 21

FACILITATOR BARKLEY: Yes. This meeting 22

is open to members of the public and some of the 23

members of the public are not in this local area. We 24

did have one request for a gentleman to attend this 25


27

meeting via conference bridge. And due to the 1

arrangements of the audio in this room it wasn't 2

possible to do it any other way than a cell phone. So 3

we're going to go to him and ask him to make a 4

statement for the period and move from there. So our 5

first speaker will be Mr. Thomas Saporito who is a 6

senior consulting associate and he actually lives in 7

Florida. So as soon as we can work having him on the 8

microphone we will have him make his statement. Are 9

we free to give it a try? 10

MS. REGNER: Go ahead. Yes. Go ahead, 11

Mr. Saporito. 12

MR. SAPORITO: Is it my turn to speak? 13

MS. REGNER: Yes. 14

MR. SAPORITO: Okay. Can you hear me 15

okay? 16

FACILITATOR BARKLEY: As best we can, yes. 17

MS. REGNER: Yes, go ahead. 18

MR. SAPORITO: All right. My name is 19

Thomas Saporito. I'm the senior consultant with 20

Saprodani Associates and I'm located in Jupiter, 21

Florida. I would like to comment on the NRC's 22

environmental review but before I do that I want to 23

state that, you know, I'm very upset at the NRC's 24

refusal to honor my enforcement petition filed under 25


28

10 CFR 2.206 with respect to the Limerick nuclear 1

plant. The NRC denied that petition on the basis that 2

I would have an opportunity to intervene on this 3

proceeding through the NRC's judicial process. 4

However, that's not available to me. I made that 5

quite clear in the 2206 petition. Now, I don't have 6

standing as a United States citizen because of my 7

physical location in Jupiter to intervene in a 8

proceeding in Pennsylvania where this plant is 9

located. The NRC staff is incorrect in their opinion 10

and they have a legal obligation to honor that 11

enforcement petition and to provide an opportunity for 12

me to address the Petition Review Board. So I want to 13

put that on the record and I'm asking the NRC to look 14

into that issue. 15

With respect to this environmental 16

petition the fellow who spoke earlier from the NRC, I 17

don't recall his name. It was very hard for me to 18

hear through this communication his name. But anyway, 19

one of his comments was exceptionally incorrect and he 20

misinformed the public. And I'd like to correct that 21

statement. He stated that the NRC is extending the 22

original operating license which was granted by the 23

NRC for a 40-year period of time that that initial 40-24

year license was not based on safety considerations or 25


29

technical considerations. But that's absolutely not 1

true and there was recently a year-long investigative 2

report done by the Associated Press who interviewed 3

expert nuclear personnel, engineers, safety engineers 4

in the nuclear industry who told them that the 40-year 5

licenses issued by the NRC for 104 nuclear plants in 6

the United States was based on safety and technical -- 7

safety technical analysis. So these proceedings, 8

these license extension proceedings like the one we're 9

currently at are a rubber-stamping of these 20-year 10

license extensions. This is in fact a foot race 11

between the Nuclear Regulatory Commission and the 12

United States Congress where Congress wants to stop 13

this process, put a moratorium on the re-licensing 14

until the Fukushima disasters can be fully understood 15

and the enhancement enacted in August for our power 16

plants here. This particular nuclear plant, these 17

plants, you know, their license is already good till 18

2024. Why are we here now 12 years ahead of time 19

trying to extend this license? And the only reason is 20

because it's a foot race the NRC's in with Congress 21

and nothing more. This has nothing to do with 22

protecting public health and safety, it's the NRC's 23

zeal to continue to rubber-stamp these license 24

extensions without allowing citizens due process like 25


30

I already talked about and without doing a cost-1

intense and thorough environmental review. 2

And with respect to the NRC's 3

environmental review the NRC in my view failed to 4

properly consider the embrittlement of this nuclear 5

reactor vessel. When these nuclear reactors are 6

operating the neutrons cause the metal in the reactor 7

vessel to become brittle over time. And after 8

numerous years of operation these reactor vessels 9

could crack because they're so brittle. But the NRC 10

doesn't properly evaluate that and the NRC doesn't 11

require the licensee to do destructive testing and 12

analysis of the reactor's metal vessel prior to 13

rubber-stamping a 20-year extension to these licenses. 14

Twenty years from now, oh actually 20 years from 2024 15

which will be 2044 this reactor is going to be even 16

more critically brittle and the NRC's not going to 17

understand the dynamics of that and the reactor could 18

crack and it's going to melt down because you can't 19

recover from a loss of coolant accident of that 20

magnitude. So that's one point. 21

The other point is the NRC's Commission 22

over there in Rockville, in the White Flint Building, 23

they recently adopted a new policy with respect to 24

evacuations. They want these licensees to update 25


31

their evacuation plans. Now, I would hope that the 1

NRC staff has made that requirement to the Limerick 2

licensee so that the people near and around within 15 3

miles of the nuclear plant can properly and timely 4

evacuate the area. Again, the Associated Press's 5

investigation, year-long investigation shows that the 6

populations around these nuclear plants increased 7

tenfold over the years and that the roads and the 8

congestion, you can't timely evacuate these areas. 9

And the NRC keeps pushing these evacuation plans onto 10

the licensee but the NRC doesn't enforce its 11

regulation or properly review if these plans are even 12

effective. 13

The NRC is required under the law in this 14

review, the environmental review to consider renewable 15

energy sources, alternatives. And that means need. 16

Is there really a need for these two nuclear plants to 17

operate and the answer is no. Simply stated if all 18

the customers who receive power from these nuclear 19

plants were to simply remove their hot water heaters 20

and replace them with on-demand electric water heaters 21

you would reduce the electric base load demand by 50 22

to 70 percent. You wouldn't need either one of those 23

nuclear power plants to operate. If you take that 24

further and introduce other energy conservation you 25


32

would actually have the licensee shut down more of 1

their other power plants because of you would need a 2

demand. If you take wind energy which is plentiful up 3

there in Pennsylvania and even the new solar panel 4

which can operate when the sun isn't shining on a 5

cloudy day you could replace even more operating power 6

plants. So these renewable energy sources even with 7

respect to wind energy since you have a common grid 8

throughout the United States you can have wind farms 9

generate power to a common grid point and supplying 10

the power that these nuclear plants are now providing. 11

The NRC's required under the law to consider these 12

alternatives to extending this license. And I would 13

hope that the NRC's final evaluation and review shows 14

a complete and thorough analysis of all these 15

renewable energy sources including installing on-16

demand hot water electric heater and doing an analysis 17

of how many megawatts you're going to take off the 18

grid and based on those evaluations make a licensing 19

determination whether or not this license should be 20

extended. Because 20 years from now all these 21

renewable resources are going to be all that much more 22

advanced and capable of supplying all that much more 23

power than they're currently supplying. So those are 24

my comments and I would hope that the NRC takes them 25


33

seriously and applies them to this license renewal. 1

And I hope everybody heard me. 2

(Applause) 3

MS. REGNER: Can you hear that? They're 4

clapping. 5

FACILITATOR BARKLEY: Okay, at this point 6

I'll call back Mr. Saporito later and thank him for 7

his remarks and for being succinct in his remarks. 8

It's awfully awkward to provide comments via this 9

avenue. 10

The first three people I would like to 11

call are actually individuals who did not speak this 12

afternoon so I'd like to start with them. Firstly, 13

Jeff Chumnuk, then Daniel Ludewig, and then finally 14

Catherine Allison. So Jeff, if you could lead off. 15

MR. CHUMNUK: Hi, my name is Jeff Chumnuk 16

and I'm a member of Borough Council with Pottstown 17

Borough. And my comments tonight are more I guess 18

from my perspective as a newly elected official with 19

the generating station. About a year ago I had the 20

opportunity to go down to the generating station and 21

meet with Joe Saffron and the first part of my meeting 22

had to do with looking for some support for the 23

Pottstown Soapbox Derby. Through some conversation 24

while we were standing outside you know Joe 25


34

enlightened me a little bit on what Exelon and the 1

generating station do for the surrounding communities, 2

whether it's supporting our firefighters, police 3

departments and other civic organizations. You know, 4

from a Pottstown perspective they help us with our 5

yearly borough cleanup, our Salvation Army and now the 6

Soapbox Derby. Thank you. 7

And we were standing outside that day, it 8

was pretty nice out, and our conversation led to the 9

power plant itself. We were standing there looking 10

around, it's a pretty impressive sight. So I asked 11

him about, you know, possibly having a tour for 12

municipal officials. He said he would look into it 13

and see what he could do. A couple of months later he 14

got a group of about 20 of us and gave us a tour of 15

the plant one evening. And I have to say that from 16

the time we walked through the front gates and past 17

the security as our tour progressed, you know, 18

throughout the plant safety was paramount. Whether 19

you were having explained what the different colors 20

are on the different panels and what they mean to 21

different failsafes, why you walk certain areas 22

certain ways and what lines you had to stand behind, 23

you know, safety was paramount with them. You know, 24

from the environment, I'm looking around and this 25


35

place is spotless. And I asked why and it's because 1

they can't afford to have dirt or lint or fuzz balls 2

around because of static electricity because it could 3

create issues. So from that aspect I thought it was a 4

good tour and it made me feel good about the safety 5

aspects there. 6

To finish our tour we ended up in the 7

control room upstairs. And I'd say maybe a dozen or 8

so individuals up there monitoring you know everything 9

going on within the plant and around the plant. And 10

again, explaining the failsafes and why they're 11

double-, triple-checked to eliminate human error. It 12

was just very impressive and as an elected official to 13

go down and take a tour of the plant and understand 14

how it operates. I know when I left I personally know 15

how to issue a concern with the generating station. I 16

know I felt a lot better and a lot safer going home 17

that night. And it was also good to realize, you 18

know, as one of our region's largest employers now 19

that they are willing to give back to the community 20

and keep safety first. So thank you, I just wanted to 21

make those comments. 22

(Applause) 23

FACILITATOR BARKLEY: Thank you, Jeff. 24

Daniel? 25


36

MR. LUDEWIG: I'm Dan Ludewig. Just two 1

questions. One would be what are we going to do with 2

the 20 years of spent rods and how are you going to 3

take care of those. And secondly, if we don't get the 4

license which I doubt but what would -- how would we 5

get electric if the license were canceled? I don't 6

know who answers this. 7

FACILITATOR BARKLEY: I'll ask Lisa to 8

speak. 9

MS. REGNER: Yes, the spent fuel rods. 10

Limerick is licensed for an individual spent fuel pool 11

facility. They offload the spent fuel. Once they've 12

cooled to a certain level they will put those into dry 13

cask storage and store those onsite. In the 14

environmental review that's looked at generically. 15

Limerick does have storage for the spent fuel rods. 16

That's an ongoing, it's onsite and part of their 17

reactor oversight process as well. So the residents 18

that work at the plant monitor the safe operation of 19

those facilities. 20

The second question, where would the power 21

come from if Limerick were shut down? There are 22

alternate power facilities in the area. Dave, you 23

want to give that a try? 24

MR. WRONA: I'm David Wrona, a branch 25


37

chief in the Division of License Renewal with the 1

Nuclear Regulatory Commission. The choice of what 2

electricity is used is not the Nuclear Regulatory, 3

it's not under our purview. As Rob and Lisa had on 4

their slides our mission is to protect the public 5

health and the safety from the commercial use of 6

nuclear power. So if the decision is to have a 7

nuclear power plant then the Nuclear Regulatory 8

Commission is here to ensure the public health and 9

safety of that plant. But we don't get involved with 10

the decisions of exactly what type of power plant will 11

be used to power, put electricity on the grid. 12

In terms of the spent fuel, spent fuel is 13

an issue that we will address in our Environmental 14

Impact Statement. So when -- we're still developing 15

that report. We're very early in the stages of that. 16

When it's published you'll be able to see our 17

analysis on spent fuel and we'll be back in 2013 -- 18

2012, sorry, to receive comments on that report. 19


Catherine? Catherine, our longest speaker today was 21

Mr. Cuthbert, eight minutes. I will not interrupt you 22

before eight minutes. 23

MS. ALLISON: I appreciate that. He was 24

very concise and he had some great information for us. 25


38

Can everyone hear me in the back row? I am Catherine 1

Allison and I was born and raised in this area so as 2

far as the NRC wanting to know how this impacts the 3

area I know it very well. I've also traveled the 4

world so, Europe, et cetera. So did anyone not be 5

able to hear me, just raise your hand. You're good? 6

Okay. 7

One thing I wanted to say is the NRC 8

tonight is doing a scoping basically for environmental 9

purposes for the re-licensing. What I wanted to say 10

is for years everyone, I'm being general here, but 11

most people have been talking about the effects of 12

like, you know, cancer, you know, the impact on the 13

clean air, clean water which things we are all 14

concerned about and a lot of us just didn't do 15

anything about it even though we were very concerned. 16

Now lately with the -- unfortunately it's 17

a reality now that we have hurricanes, more tornadoes, 18

tsunamis throughout the world. And I hate to say it 19

but it is a reality now that we have terrorist attacks 20

and Limerick is definitely one. I don't want to be 21

blowing this out of proportion but it's just something 22

that I know that we've all been concerned about, not 23

wanting to say yes, Limerick, and all the people that 24

built the power plant and the company say oh, there's 25


39

no impact to the air and the water pollution and so 1

forth. So we've kind of just blinded our, you know, 2

selves to that and let's believe then, okay, let's 3

take a minute. Let's really believe that there is no 4

impact in our clean air, clean water and those type of 5

things and cancer, et cetera. Let's just go into the 6

new reality which is terrorist attacks which would 7

happen. Let's just say for example there was human 8

error there with the spent fuel rods and something 9

happened, or a radiation leak. I just drove tonight 10

from King of Prussia. Talk about evacuation when 11

these natural disasters and realities hit us. One 12

accident, two hour backup, almost no exaggeration, one 13

thousand cars. There will be no evacuation. I don't 14

want to be like scare tactics here but like I said, 15

the weather and so forth, natural disasters has really 16

been hitting the whole United States and the world 17

lately so it's a reality. 18

There was flooding after the hurricane 19

that we just had. Five days later there was roads 20

closed in Pottstown, in North Coventry, East Coventry. 21

There were, when I tried to get home from work right 22

on Route 724, no exaggeration again from all the back 23

roads about 500 cars. There will be no evacuation and 24

I certainly hope that people understand I'm not trying 25


40

to be scare tactics. I see this. I'm sure a lot of 1

you have seen this and been in these situations. All 2

with a little bit of flooding. What this does to the 3

roads. Again, there will be no evacuation. 4

So from day one I think power plants never 5

should have been built but now that they are here why 6

would we ever want to re-license. And as our 7

gentleman caller just said, I believe his name was 8

Thomas, he was very eloquent. He was stating the fact 9

why are we re-licensing them, what, 12 years ahead of 10

time. To me that is absurd. Like maybe a year before 11

or they have to do some studies, two years before. 12

Why do they want us, and I love Thomas's words, 13

rubber-stamp something? Twelve years beforehand to go 14

into what, 2024 for Unit 1 was it and 2029 for Unit 2? 15

Why do they need to push this licensing renewal? 16

You've got to stop and think. People, go home, think 17

about that. I'm not an expert like evidently our 18

caller Thomas was but again, I'm concerned about human 19

life. This is what I have at the top here. We are 20

talking about human life. What's more important, not 21

all this electricity that we need for all our cell 22

phones and everything. In a way we are responsible 23

for the fact that PECO and all these other Exelon 24

companies are building power plants. I myself you 25


41

know am guilty of a lot of this but let's just maybe 1

for a solution besides the wind and solar power and 2

everything stop using all this new technology. Yes, 3

you need it for some jobs and businesses, it's good 4

for certain things, but let's not overindulge where we 5

need so much electricity that we are willing to risk 6

our lives. Cancer, polluted water. There's no 7

drinking water anymore. People have to pay to buy 8

water that comes from natural springs. But you're 9

using plastic bottles, you can't even trust that. 10

But this whole world has kind of just 11

changed from you know nature. Let's get back to 12

nature, let the -- instead of having all the young 13

teenagers on their cell phones texting, using more 14

electricity, that again it's going to cause cancer for 15

them. Everybody has to stop and think why do we need 16

the power plants? We really don't and again, Thomas, 17

our wonderful caller mentioned some alternatives like 18

the solar power, wind, but I'm just saying we are 19

using so much electricity and stupid little video 20

games on the computers. People get on the computers 21

for hours at a time doing nonsense. That's taking up 22

electricity where again why do you need all this 23

electricity? It could be causing cancer in your 24

children. I am not that old but I'm not that young, 25


42

but I hate to tell you I have so many friends and 1

coworkers and people that are only 35, 40, 50 years 2

old, cancer. And why? We have to stop and think. Go 3

home, don't just always, you know, just go watch TV 4

and get on your computer. Stop and think what we're 5

doing to ourselves, our bodies, our children, our 6

grandchildren. 7

This is again, this licensing renewal is 8

coming down to human lives, the quality of our lives. 9

Again, why all this cancer? Microwaves and 10

electricity. So I won't go on and on, but I just 11

think us as a group can't just all be just complaining 12

about the power companies, we are the ones using the 13

electricity. That's all I'm saying. Maybe we should 14

cut back and we won't need power plants. Thank you. 15

(Applause) 16

FACILITATOR BARKLEY: Thank you, 17

Catherine. The next three people I'd like to call 18

would be Jeffrey Norton of the P. Energy Alliance, 19

then Bill Maguire and then finally Lorraine Ruppe. 20

Mr. Norton? 21

MR. NORTON: Good evening. My name is 22

Jeffrey Norton and I'm here to represent the 23

Pennsylvania Energy Alliance which is an independent 24

grassroots diverse organization made up of community 25


43

leaders and organizations who promote nuclear power as 1

a clean, safe, reliable and affordable source of 2

power. I'm going to be making essentially five points 3

in support of license renewal for Limerick Generating 4

Stations and they are that, number one, nuclear energy 5

lowers electricity prices, it protects our environment 6

against greenhouse gases, it strengthens our local 7

economies and it is safe. 8

With regard to my first point in lowering 9

electricity prices the Limerick Generating Station has 10

reduced wholesale energy costs in Pennsylvania by $880 11

million in 2010 thus lowering electricity prices for 12

all consumers. It operates around the clock thereby 13

stabilizing the nation's electricity distribution 14

system and the electricity marketplace. The average 15

electricity production costs at nuclear plants have 16

actually declined more than 30 percent in the past 10 17

years due to various efficiencies. Nuclear power is 18

cheaper to produce than other forms of electricity 19

generation such as coal and natural gas, and helps 20

moderate the price of electricity for consumers. 21

My next point is that Limerick Generating 22

Station and nuclear plants strengthen our local 23

economies and it is a valuable economic driver for the 24

Commonwealth of Pennsylvania. Limerick Generating 25


44

Station contributes $113 million annually in direct 1

economic contributions to the Pennsylvania economy 2

through various employee wages and salaries, purchase 3

of goods and services from other Pennsylvania 4

businesses and in property tax payments to the local 5

governments. Limerick Generating Station also 6

contributes generously as we've also heard and in fact 7

in 2010 contributed $600,000 to various community 8

organizations. Limerick has over 800 full-time 9

employees and employs more than 1,000 skilled 10

temporary contract employees during annual refueling 11

outages. A significant percentage of the current 12

nuclear plant workforce will reach retirement age in 13

the next 10 years creating a demand for high-paying 14

jobs in the nuclear industry. Yes, Limerick 15

Generating Station is one of Pennsylvania's most 16

valuable economic and energy assets and the 17

commonwealth should embrace it. 18

My third point is that nuclear energy 19

protects our environment from greenhouse gases and 20

reduces the need to generate electricity from fossil 21

fuels. If Limerick Generating Station were retired 22

from service replacing the electricity would require 23

increased natural gas-fired or coal-fired generation. 24

Nuclear energy is the nation's largest source of 25


45

carbon-free electricity and is critical to our 1

nation's environmental, security and energy goals. 2

My next point is that nuclear energy is 3

safe. It's always on, it's stable, it's a reliable 4

source of electricity and the station here at Limerick 5

has been built with multiple redundant safety layers. 6

And the workforce is committed to best practices and 7

continuous improvement. It is also important for our 8

nation's quest to be energy-independent. According to 9

the Bureau of Labor Statistics it's safer to work at a 10

nuclear plant than in industries such as 11

manufacturing, real estate and finance. And according 12

to the Department of Energy a person receives more 13

radiation exposure flying from Baltimore to Los 14

Angeles than by standing near a nuclear plant 24 hours 15

for a year. 16

On a personal note I've been inside 17

Limerick Generating Station several times. I've also 18

lived within 30 miles with my four boys and wife next 19

to the Limerick Generating Station and also Three Mile 20

Island. I feel safe, secure and comfortable. That is 21

why I'm in support of the re-licensing of the Limerick 22

Generating Station. Thank you very much. 23

(Applause) 24

FACILITATOR BARKLEY: Thank you. Mr. 25


46

Maguire? 1

MR. MAGUIRE: Good evening. My name is 2

Bill Maguire and I'm the site vice president at 3

Limerick Generating Station and I have overall 4

responsibility for the safe and reliable operation of 5

the facility. A little bit about my background. I've 6

got 25 years of experience in the nuclear industry 7

starting my career at Limerick station as an engineer. 8

I went on to receive a license to be a senior reactor 9

operator at the plant and was involved in the direct 10

supervision of the operators of the plant and was the 11

on-shift manager of the facility for many years. I've 12

worked at a few other nuclear facilities around the 13

country in capacities such as operations director, 14

maintenance director, plant manager and was recently 15

the site vice president at the Peach Bottom Atomic 16

Power Station before coming back to Limerick station 17

in May of 2010. 18

Operating Limerick Generating Station 19

safely and reliably is a key responsibility for all of 20

the employees at Limerick Generating Station, one that 21

the folks at the station take very seriously as a 22

personal commitment to themselves and to the industry 23

and to the community at large. An important part of a 24

thriving community is safe and reliable electricity, 25


47

and Limerick has been a part of that key aspect of a 1

thriving community for the last 25 years. And as we 2

look at the growing demand for energy, safe and clean 3

energy in the future for Pennsylvania and for our 4

nation Limerick is a key component of that future. 5

And we have petitioned the NRC through the license 6

renewal process to extend our operating license for an 7

additional 20 years. 8

The U.S. nuclear industry consists of 104 9

nuclear reactors and those 104 reactors provide 10

approximately 20 percent of the U.S. electrical 11

supply. And that's been a pretty steady number over 12

the years. Even though there haven't been a lot of 13

new nuclear plants brought onto the grid in those 14

years the plants continue to run more and more 15

efficiently, keeping up with the growing demand for 16

electricity. Seventy percent, or excuse me, 17

approximately 70 of the 104 reactors have already been 18

through the license renewal process and have received 19

approval for a license renewal. 20

Limerick Generating Station operates in a 21

manner that preserves the environment. We perform 22

over 1,700 tests per year that look at the water, air, 23

fish, land, cow's milk, vegetation and the like to 24

ensure that we are not adversely impacting the 25


48

environment. We also maintain a chain of radiation 1

monitors around the plant to make sure that we do not 2

have an adverse impact from the operation of the 3

facility. 4

In 2005 the environmental management 5

systems at Limerick Generating Station received 6

certification under the strict criteria of the 7

International Organization for Standardization (ISO). 8

This is a common industry recognition and the 9

certification that we received credit for is ISO 10

14001. And this is an internationally recognized 11

benchmark for environmental management. And the ISO 12

14001 certification requires a commitment to 13

excellence not only in meeting our regulatory 14

requirements but also in the prevention of pollution 15

and to ensure continuous improvement in our 16

environmental systems. 17

In 2010 the Wildlife Habitat Council 18

recognized Limerick Generating Station's commitment to 19

environmental stewardship by awarding us the Wildlife 20

at Work certification. And this distinction was 21

awarded for our commitment towards establishing long-22

term wildlife habitat enhancements that maintain food, 23

water, cover and space for animal species that are 24

living in the power station's landscape. 25


49

To ensure Limerick continues to operate 1

safely for years to come Exelon continues to invest in 2

Limerick. Since 2010 over $200 million of investment 3

has been made into new safety systems and the 4

reliability of our electric generation components. 5

And since 2001 over $40 million have been invested in 6

our security systems. 7

Our investment in the future doesn't stop 8

with investment in equipment. We've hired over 100 9

new employees in the last three years and we maintain 10

a steady-state workforce of approximately 850 11

employees. And during our annual maintenance and 12

refueling outages that population grows temporarily 13

for about a month by another 1,500 to 2,000 employees, 14

bringing a boost to the local economy. 15

Over the past 25 years Limerick has been 16

one of the best performing and most reliable plants in 17

the nuclear power industry. During that time the 18

plant has set several records for continuous days of 19

operation and has been recognized by the industry for 20

our reliable performance. In March 2010 Limerick 21

completed a successful run of 727 continuous days on 22

our Unit 1 plant and this represented the second 23

longest continuous run for a boiling water reactor in 24

the United States. While we do not set out to break 25


50

records, continuous operations are one indicator of 1

the excellent human performance and equipment 2

reliability that Limerick strives for every day. 3

We also take pride in our investments in 4

the community. In 2010 Limerick Generating Station 5

donated more than $600,000 in the community in 6

contributions to the United Way, fire and ambulance 7

companies, educational, health and youth 8

organizations, and many of our employees serve as 9

volunteers in the local community and around the 10

plant. In conclusion, Limerick Generating Station 11

looks forward to working with the Nuclear Regulatory 12

Commission in the review of our license renewal 13

application. And we thank you for this opportunity to 14

address the public this evening. Thank you. 15

(Applause) 16

FACILITATOR BARKLEY: Thank you. 17

Lorraine? 18

MS. RUPPE: Hi, my name is Lorraine Ruppe. 19

Thanks for letting me talk again this evening. I am 20

speaking here tonight to represent the children and 21

future generations, especially in our community. 22

Residents here are fearful about the possibility of 23

disasters here in light of Fukushima in March 2011 and 24

since the earthquake and Hurricane Irene in August 25


51

2011 affecting our area. Climate changes, et cetera, 1

are causing disasters everywhere and continuing to get 2

worse. Increasing floods, droughts, earthquakes, 3

tornadoes have made us all feel insecure making 4

nuclear power increasingly risky, especially with the 5

Limerick plant basically in our backyards. Any 6

earthquake that comes through this area could be a 7

possible Fukushima, Chernobyl or Three Mile Island. 8

Four months had passed since the NRC failed to get 9

back to me when I asked how close the Ramapo fault 10

line is to the Limerick nuclear reactors. I was told 11

today earlier to call Andrew Rosenbaum so I will 12

hopefully receive that information. 13

Indian Point nuke plant was sketched as a 14

possible terrorist target in reference to the 9/11 15

attacks. A suspected terrorist worked at Limerick for 16

years without the industry knowing it. How scary is 17

that? 18

The Pacific Ocean is now severely 19

irradiated by Fukushima. Radiation impacts of 20

Fukushima equaled over 20 Hiroshima bombs when I last 21

researched. Our drinking and bathing water here is 22

being continuously polluted by Limerick every day, 23

24/7, for years with radiation and unfiltered toxic 24

contaminated mine water thanks to the NRC and Exelon. 25


52

This is disgusting. Most of us have to depend on 1

this water, especially for bathing. Some of us pay 2

extra for water filtration or drink bottled water 3

because we are afraid to drink from the Schuylkill and 4

because it tastes really bad now. Imagine how toxic 5

it would be 18-plus years from now even if there is 6

any water left. 7

There has been increased particulate 8

matter in the air and other toxics from Limerick 9

causing increased asthma, heart attacks and strokes. 10

And to add insult to injury Limerick was granted a 11

permit to allow an eightfold increase in air pollution 12

since 2009. Cancer rates in our area have skyrocketed 13

since Limerick has been up and running in the '80s and 14

rates have steadily increased. The Tooth Fairy 15

Project showed high levels of strontium-90, a 16

radionuclide, in the baby teeth of children living 17

nearest to the nuclear plants. Baby teeth near 18

Limerick plant had the highest levels in the whole 19

United States. So all this stuff and God knows what 20

else is in our bodies now thanks to the Nuclear 21

Regulatory Commission that, to put it nicely, is less 22

than enthusiastic about protecting us. 23

Solar wind, geothermal, ocean thermal, 24

energy conservation and efficiency are now cheaper 25


53

than nuclear power along with being clean and safe. 1

The Department of Energy 2006 report stated that solar 2

alone could provide 55 times our entire nation's 3

energy needs which leads me to the point: there have 4

been numerous studies proving the many dangerous and 5

deadly consequences of nuclear power. There is no 6

denying the massive devastation it has already caused 7

and will continue to cause indefinitely. But the 8

industry still goes on in their trance-like 9

indifferent fashion as if everything is safe and 10

wonderful and will continue to be 18-plus years from 11

now on until 2049 for our community. 12

This is what really scares us the most. 13

This is beyond unethical behavior from the industry. 14

The NRC has turned into a culture of secrecy, hiding 15

the dangers and sweeping the problems under the rug. 16

The industry's addiction to money and power have 17

blinded them to moral life and death issues and facts 18

set right in front of their faces. But my big 19

question of the day is why is Exelon applying for an 20

extension 18 years ahead of time. Thank you. 21

(Applause) 22

FACILITATOR BARKLEY: Okay, thank you. We 23

have had seven people speak and we have six more who 24

signed up for the remainder of the evening. The next 25


54

three people I'll call are Donna Cuthbert, followed by 1

Mike Gallagher and then followed by Dr. Fred Winter. 2

Okay, Donna. 3

MS. CUTHBERT: You know, after hearing 4

some of these gentlemen speak tonight I feel like I'm 5

living in fantasy land. For somebody to get up here 6

and actually say that there's no adverse impacts from 7

Limerick nuclear power plant is insanity. It is 8

unbelievable. I have spent the last 11 years 9

reviewing permits from Limerick nuclear power plant. 10

They are a major air polluter under the Clean Air Act 11

and to say they're not doing it anymore, they just 12

asked for the conditions that would allow an eightfold 13

increase in dangerous air pollution that actually is 14

claimed to kill people, thousands of deaths per year. 15

And they asked for an eightfold increase. 16

As a matter of fact, these are all the air 17

pollution sources and the pollutants they list in 18

their own permit. If you add that to all the 19

radiation emissions there's a broad range of 20

radionuclides. For somebody to just claim that it's 21

only tritium going into the water is insanity. It's 22

unbelievable what they expect people to believe. I 23

encourage everybody to go back to the table we have 24

and take a good look at that Schuylkill River board. 25


55

They are destroying the Schuylkill River. There was 1

never enough water in the Schuylkill River to sustain 2

this nuclear plant from the very beginning and now 3

we're seeing the consequences of that and they put 4

more and more pollution in it. They want to pump mine 5

water in to supplement the flow for Limerick. It's 6

contaminated and they don't filter it. And they're 7

actually asking for a huge, four times Safe Drinking 8

Water standard increase in total dissolved solids 9

which carry a lot of toxic pollutants. So they put 10

radiation into the river 24 hours a day, 365 days a 11

year, and now they're asking for these huge increases 12

and people have the nerve to get up here and say that 13

they have no environmental impacts. Frankly I've had 14

enough of this deception at the expense of public 15

health. I am sick of it. 16

The facts show, when we looked at Exelon's 17

thing for environmental harms they say they were clean 18

energy. The facts show Limerick isn't clean, it is 19

filthy. It's not safe, it's a ticking time bomb. And 20

nuclear power, they say it's always on. That's not 21

true either as evidenced by shutdowns, some for long 22

periods caused by earthquakes, tornadoes, hurricanes, 23

fires, heat and drought and more. It clearly isn't 24

always on in Japan. So when you take all of this 25


56

together and you look at all the ways that they 1

pollute our environment with radiation and all the 2

other toxics, every day Limerick operates our children 3

face more risk. And that's what it's all about. It's 4

about the health of our region. 5

The sooner this place closes the better 6

off we'll all be. Even if you look at infant 7

mortality rates we have higher infant mortality rates 8

and neonatal mortality rates far above state averages 9

and even above Philadelphia and Reading, and we've had 10

these for quite awhile. The fact is when babies are 11

the most vulnerable in the womb what else would we 12

expect? And by the way, for those of you who have 13

been saying that ACE data is anecdotal today I have 14

news for you. This infant mortality report for 15

example is state data reported by EPA in 2003. Every 16

cancer statistic that you see back there is based on 17

Pennsylvania Cancer Registry statistics or CDC 18

statistics. So it is not anecdotal, those are the 19

cancer increases, those are the cancer above the 20

national average that have happened here since 21

Limerick started operating. That is a fact. 22

So it's not anecdotal and the fact of the 23

matter is I thought this was about the environment but 24

apparently it's about money. So I decided that 25


57

between the sessions I was going to change things 1

around a little bit. I could talk about the 2

environmental impacts of this place for a whole week 3

it's so bad. And I've got all the documents in our 4

office to prove it. Let's talk about, let's take a 5

minute now though and we're going to talk about the 6

cost. What is this place actually costing us? Let's 7

just think about cancer for example. We have so many 8

cancers above the national average. Childhood cancer, 9

92.5 percent higher than the national average. Think 10

about that. We track the cost of one child with 11

cancer diagnosed at six months to two years and up 12

until that time it was $2.2 million. How many more 13

kids have that above the national average? Cost that 14

out and how many other cancers are above the national 15

average? You do the math. Figure that out. 16

How about the customers that paid -- I 17

hear them talk about how great the costs are for 18

Limerick. We paid for Limerick from 1985 to 2010 in 19

our electric bills. And in fact the electric that was 20

supposed to be too cheap to meter turned out to be 55 21

percent above the national average by 1997. So that's 22

how cheap Limerick electric is. 23

Then you take the property taxes. They 24

tried to get zero for their property taxes by the end 25


58

of the '90s and didn't pay any property taxes until 1

the early 2000s at which time they paid $3 million 2

instead of the $17 million they were supposed to pay. 3

So when you think about that no wonder Exelon's 4

willing to throw around a couple million in the 5

community. They owe this community a lot more than 6

what they're giving out. 7

(Applause) 8

MS. RUPPE: So then there's the cost for 9

the pollution they're putting in the river. They're 10

asking for increases in pollution. They want to put 11

more mine water in. They want to increase the total 12

dissolved salts. That's going to cost water treatment 13

systems a lot of money to try to -- for extra 14

treatment for that. It can even break down their 15

equipment, some of the stuff that's coming out of the 16

mines. And when you think about it who actually 17

ultimately pays that cost? We do. We pay for 18

increased costs for our water because they're having 19

to do that at the water treatment systems. And it 20

seems to me that if you really take a good look at 21

things Limerick has got to be the major cause for the 22

radiation in Philadelphia's water. 23

So all in all taken as a whole this place 24

has unprecedented environmental harms. There is no 25


59

question about that. Anybody that doesn't believe it 1

come look at the permits with me and I'll show you 2

exactly what's going on. I invite anybody to do that. 3

And the one thing that's really important 4

is that NRC and the nuclear industry are claiming that 5

age is no issue while at the same time they admit that 6

some parts are too big and too expensive to replace. 7

I frankly am really concerned about NRC accommodating 8

the nuclear industry with weakened regulations, lax 9

enforcement, negligence and unsubstantiated denials. 10

It's happened right here even with their fire safety 11

regulations that are -- we're on weakened fire safety 12

regulations even though we know that that can 13

eventually lead to a meltdown. I know my time's up. 14

Thank you. 15

(Applause) 16

FACILITATOR BARKLEY: Thank you, Donna. 17

Mike? 18

MR. GALLAGHER: Okay, good evening. My 19

name's Mike Gallagher and I'm vice president of 20

license renewal for Exelon. I have the overall 21

responsibility for the Limerick license renewal 22

application. Exelon has a great deal of experience in 23

license renewal. We've obtained renewed licenses for 24

the Peach Bottom and TMI plants in Pennsylvania, also 25


60

our Oyster Creek plant in New Jersey and our Dresden 1

and Quad Cities plants in Illinois. Just briefly 2

about myself, I've been working in the nuclear power 3

industry for 30 years. I was a licensed senior on a 4

reactor operator at Limerick and also the plant 5

manager at Limerick previously. I've worked at two 6

other nuclear facilities and in our corporate offices. 7

So Mr. Maguire, the site vice president of 8

Limerick, spoke about the reasons for renewing the 9

license for Limerick. I'd like to speak to you 10

briefly about the process that we took for preparing 11

this license renewal application and the amount of 12

work and engineering analysis that we put into 13

preparing the application. 14

So because the Limerick Generating Station 15

can be operated safely and reliably Exelon decided to 16

pursue license renewal. So Limerick is a very clean 17

energy source. It produces no greenhouse gases. 18

Limerick is also good for the economy in that it 19

lowers market prices of electricity for the citizens 20

of Pennsylvania to the tune of $880 million per year. 21

So in 2009 we announced our intention to 22

seek license renewal. Later that year we started the 23

work necessary to prepare the application. After over 24

two years of work we submitted the application to the 25


61

Nuclear Regulatory Commission on June 22nd, 2011. The 1

application when you print it out is about 2,100 pages 2

and when you put it in binders it's three large 3

binders. That's a huge amount of information but that 4

only represents a small part of the work that was done 5

for the engineering analysis to prepare this 6

application. The total amount of engineering analysis 7

that we produced if printed out would be about 290 8

binders of information. We invested over 60,000 man 9

hours of engineering work to prepare the application. 10

Once completed our engineering work to 11

prepare the application we brought in experts from 12

outside Exelon to review the application to ensure 13

that it was complete, thorough and accurate. Our 14

total cost to prepare the application and get it 15

reviewed by the NRC will be about $30 million. 16

So there are two parts of this 17

application. It's the safety review and the 18

environmental review. For the safety review we took 19

an in-depth look at the history and the condition of 20

the safety-related equipment in the plant. We did 21

that to determine whether the necessary maintenance 22

was being performed on that equipment and to make sure 23

that this equipment will be able to operate an 24

additional 20 years of operation. 25


62

So when you look back at Limerick when it 1

was built all the equipment was new. It was 2

thoroughly tested to make sure it performed properly 3

but like anything else equipment does age. That 4

doesn't mean it won't work but it does age and certain 5

activities need to be done with that equipment so we 6

perform preventative maintenance. We refurbish 7

equipment. We replace equipment. There's 8

modifications done to upgrade the equipment in the 9

plant. And in fact, as Mr. Maguire had stated 10

Limerick has spent over $200 million in the last two 11

years to improve and modernize equipment and enhance 12

plant operations and safety. 13

We also reviewed the calculations that 14

were performed as part of the original design basis of 15

the plant that were done to ensure that the plant 16

could operate for 40 years safely. We analyzed those 17

calculations and were able to confirm that the plant 18

would be able to operate safely for up to 60 years. 19

So overall our conclusion from our engineering review 20

was that Limerick could operate safely for up to 60 21

years. 22

We also took a look at the environmental 23

impacts of continuing to operate Limerick. We looked 24

at all aspects of continued impact of the plant on the 25


63

environment. Our conclusion is that the impact on the 1

environment are small and I use the term "small" in 2

the sense that's in the regulation. The regulation 3

defines "small" as the environmental effects are not 4

detectable or are minor. We also reviewed the 5

alternatives if Limerick would not have its license 6

reviewed and another source of electric generation 7

would have to be installed either onsite or someplace 8

to generate the replacement electricity. We concluded 9

that any other means of generation, the replacement 10

electricity would have more of an impact on the 11

environment than the continued operation of Limerick. 12

So for example, if Limerick could be replaced by a 13

wind generation facility the wind farm would have to 14

occupy between 10 and 40 percent of all the land in 15

the state of Delaware and its associated land impacts. 16

If a solar facility could replace Limerick it would 17

need to cover 32 to 50 percent of the entire land area 18

of Montgomery County. 19

So in conclusion we operate Limerick 20

safely and can continue to operate safely for an 21

additional 20 years. Limerick will provide 22

approximately 2,340 megawatts of base load electric 23

generation that's not only safe but clean, reliable 24

and economical. Continued operation of Limerick will 25


64

benefit this community, the Commonwealth of 1

Pennsylvania, and our nation. Thank you. 2

(Applause) 3

FACILITATOR BARKLEY: Thank you. Go 4

ahead, Fred. 5

DR. WINTER: Thanks. That's fine. Good 6

evening, folks. As a physician practicing radiology 7

for over 50 years I still have a strong concern about 8

cancer sensitivities from harmful radiation exposures. 9

Now my medical colleagues are sharing the same 10

concerns because we have seen our cancer rates 11

increase since the Limerick power plant started as 12

Donna was saying. 13

Now especially the Pennsylvania thyroid 14

cancer rates are the highest in the United States, 15

according to the National Centers for Disease Control, 16

jumping to 78 percent higher here than in the national 17

average everywhere. Now, some of my friends have 18

argued with me and they say Fred, the reason why we're 19

having so many more cancers is because people are 20

getting so much older. Well, I don't think that makes 21

sense because there are other areas like Pottstown 22

around with the same healthy environment that don't 23

have nearly this high cancer rate. So that doesn't 24

make sense. 25


65

Now, you wonder why some of our medical 1

and cancer fundraisers haven't reacted with more 2

responsibility in order to stop what's happening. 3

Yes, we are creating our own kind of terrorism. It's 4

the same, almost a form of terrorism by allowing all 5

these harmful exposures to exist. Now, I attended in 6

Japan a Hiroshima clinic right after World War II when 7

I was in the service. Excuse me. I have to sit down? 8

Oh. Anyway, when I was in the service at this 9

Hiroshima clinic after the atom bomb hit and you can 10

just imagine what I saw and what awful memories I 11

have, particularly of little kids that were going to 12

die any day and so many people injured. Anyway, it 13

left me with very sad memories. Now I can't help but 14

worry about our kids who are actually more vulnerable 15

than adults. And of course what is happening here 16

will be taking a lot much longer to happen than what I 17

saw but it sure is not good. 18

Besides harmful power plant exposures we 19

have environmental disasters and a concern about our 20

nearby earthquake fault and others in the eastern U.S. 21

And then there are radioactive spent fuel materials 22

that somebody mentioned sitting around but supposedly 23

protected. 24

We can't control the use of nuclear power 25


66

in the rest of the world. Everywhere nuclear power is 1

being used. Now I don't know whether -- by the way, I 2

should remind you that there are some scientists who 3

are predicting that it may take a little while, maybe 4

a hundred years, but they're predicting that mankind 5

will be completely destroyed by the effects of nuclear 6

energy. That's saying a lot, I know. 7

So please ask your reliable politicians to 8

close the Limerick power plant. Let's save America 9

for our kids and our descendants if this ever happens. 10

So I hope you will take my concerns seriously. And 11

thank you for listening. 12

(Applause) 13

FACILITATOR BARKLEY: Thank you, Dr. 14

Winter. We have four individuals who would like to 15

speak before the meeting is over with so let me call 16

all four in this order. Dan Ely to start off, then 17

Jim Beckerman, then Dr. Lewis Cuthbert, and then 18

finally Jim Derr. So Dan, are you still here? 19

MR. ELY: Thank you, Rich. It's 20

pronounced Dan Ely. I'm a resident of Limerick. We 21

are pigs. We are energy pigs. Nuclear power is a 22

great resource for us. It is particularly clean and 23

in this day and age of understanding about carbon 24

dioxide and the effect on our environment it's a very 25


67

important part of what we should consider. When I 1

went away to college to study physics I realized, 2

well, maybe I should be in nuclear engineering and get 3

into this sea. And I'd look at my elementary physics 4

book, elementary particle physics book and it looks 5

like hieroglyphics to me today. 6

I worked at Limerick nuclear power plant 7

and I worked for Bechtel Power Corporation in building 8

that plant. And I worked in quality assurance. 9

Quality assurance has been my life. It's very 10

important to understand that in the design of a 11

nuclear power plant there are criteria that are used, 12

particularly any engineer who has studied properly 13

knows failure mode effects analysis has to be done to 14

evaluate what possible effects come out of an incident 15

at any design, whether it's an automobile design or 16

any other design. And I have to ask because I read 17

most recently that the earthquake that occurred with 18

an epicenter in Virginia, the closest nuclear power 19

plant I understood actually took a Richter reading 20

that was higher than what the design criteria for the 21

failure mode effects analysis would have predicted. 22

It withstood that. I don't know, Bill, do you know 23

that? Did you understand that, that that was a 24

published fact? 25


68

FACILITATOR BARKLEY: We have an 1

inspection ongoing at that point right now regarding 2

the North Anna facility. So yes, it did experience an 3

earthquake beyond its original design. So far the 4

inspections have revealed no -- minimal damage. I've 5

only heard of one piece of equipment that experienced 6

even visible signs of problems. But the overall 7

analysis, this is continuing and the licensee has to 8

have permission from us to restart after an extensive 9

inspection. 10

MR. ELY: My concern is that this hastened 11

license renewal process is inappropriate for 12

engineering reasons. I worked in a variety of 13

different areas in the construction of that power 14

plant and there were continual deviations that were 15

provided, whether it was in-storage maintenance 16

monitoring of the condition of the components that 17

were used to the actual construction of that plant. I 18

could cite you several examples. 19

What I would like to ask of the public is 20

that the people that had worked at that nuclear power 21

plant take a look at this licensing renewal and 22

understand that they need to review those failures and 23

those deviations that were provided to go ahead with 24

the construction of that plant with non-conformances 25


69

that were reviewed, but not reviewed in light of what 1

we understand and know today about earthquakes or 2

other anomalies. We need to have enough time to make 3

the evaluation on those deviations. The cooling 4

pools. The fuel pool girders that are placed there. 5

There are rebar concrete reinforced supports where a 6

quality engineer, he was supposed to be accepting the 7

very highest grade of concrete to be placed in a 36-8

hour pour there and he didn't pay attention. And the 9

cofferdam was being built down in the river and up 10

comes this sand mix with a very low strength and gets 11

pumped up into those fuel pool girders in a layer and 12

the engineer said well, boy, that was a terrible 13

mistake, but it'll be okay. We need to go back and 14

take a look at all of those mistakes and make sure 15

that they're not written off because a layer in a 16

structure under load caused by an earthquake, that's 17

an issue. It might not be an issue for the strength 18

of the fuel pool girders to support those fuel pools 19

that when we see them in Japan and they catch fire 20

because they're extremely hot and you need to address 21

that. I was on that pour but I wasn't the engineer 22

that made that error, but there's a number of errors 23

that were made. And I don't see or understand that 24

the NRC or the review or the licensing application is 25


70

taking a look at those failures and those errors and 1

addressing them in light of the knowledge that we have 2

today. 3

Some people don't understand about 4

radiation and I read when the Japanese thing occurred 5

and I heard on the news a radiologist talking about 6

oh, the radiation is such a low amount. It really 7

isn't the low amount of radiation exposure that we get 8

incidentally in standing next to a nuclear power 9

plant. It's three ten-thousandths of a gram of 10

plutonium that is death for you if you breathe that 11

dust particle. It's almost certain death. And the 12

problem becomes you can't have -- and it's not going 13

to be a nuclear bomb. It's going to catch on fire if 14

the fuel pool girders were to fail and you'll have a 15

cloud of a material that in and of itself you might 16

not have radiation exposure to it but that particle 17

when it deposits itself can be an issue much the same 18

as fluoride is what causes thyroid cancer when it's a 19

radioactive fluoride. That's why we're very careful 20

in building a plant with no Teflon and no fluoride 21

components. 22

So we need to pay attention to some of 23

that engineering and I'm not certain that that's being 24

done. I'd like to see an agency or for somebody to 25


71

contact me if they know about a variety of different 1

flaws that they saw during the construction. And my 2

email address is [email protected]. Yes, I will be 3

the chair of the Philadelphia section of the American 4

Society for Quality coming up and I've been past chair 5

in the past so yes, I'm very quality-oriented and I'd 6

appreciate any feedback from people that have issues 7

with that construction. Thank you. 8

(Applause) 9

FACILITATOR BARKLEY: Okay. Thank you, 10

Dan. Jim Beckerman? 11

MR. BECKERMAN: Good evening. My name is 12

Jay Beckerman. I'm a resident of Phoenixville. I 13

found out about this meeting because I scan a lot of 14

newspaper websites. I found the notice of the meeting 15

on the West Chester Daily Local website. Didn't find 16

it in the Phoenixville paper, didn't see it in the 17

Philadelphia newspaper, didn't hear about it on any of 18

the local radio stations, didn't hear about it on 19

cable, didn't hear about it on any of the television. 20

Once a month, what is it the first Tuesday 21

about 2:00 I hear the siren that we all hear. What 22

should happen in terms of people getting notice is 23

everybody who's within the plume area should something 24

happen at Limerick should find out about this meeting 25


72

and I seriously doubt that that actually happened. I 1

think it was pure accident that I found it. Something 2

as serious as license renewal should get the same kind 3

of outreach that occurs when Limerick does what it 4

should which is to mail out every year or two to all 5

of the possibly affected homes the maps and the 6

notifications of how do you evacuate. If you're going 7

to renew a plant which happens once every 20 years I 8

don't understand why the NRC doesn't require the same 9

kind of outreach public notification so people get a 10

chance to come to one-time meetings like this. I 11

think that is a basic flaw in the NRC's licensing and 12

re-licensing procedure and I think it should address 13

that. 14

The slide behind me documents exactly two 15

libraries that the documents are going to go in. Why 16

not in my library in Phoenixville? Why not in 17

Montgomery County and Norristown and all of the other 18

public libraries that are in areas that can be 19

affected by the plume should something happen here? 20

Why are the documents in such a restricted area? 21

I'd like to switch a little bit. I've 22

been researching, I didn't even know about this ACE 23

organization. Glad to find it. I've been researching 24

on my own information about nuclear power plants and 25


73

their risks for quite awhile. An organization I ran 1

across published this book titled Insurmountable 2

Risks. The organization is called the Institute for 3

Energy and Environmental Research. It's an amazingly 4

well-researched book. I doubt very many people have 5

read it but you should. This organization is at least 6

as interested in alternative energy sources as it is 7

in having put the effort in to document what are the 8

problems with nuclear power engineering-wise. The man 9

who's head of this organization is a nuclear 10

scientist, a guy named Arjun Makhijani. He's a PhD 11

nuclear scientist. These are first-class researchers, 12

this is PhD-level stuff written for popular 13

consumption. So I'll be glad to make more detail 14

about the book available to anybody who wants to know. 15

A few questions I have, one that I've been 16

thinking about for a long time. I wonder how many 17

people here are aware of something called the Price 18

Anderson Nuclear Industries Indemnity Act. Who knows 19

about that? The title alone should give you some 20

pause. Why do we need a nuclear industries indemnity 21

act? What does it do? What it does is it puts a 22

ceiling of a few hundred million dollars on the 23

liability that nuclear power plant owners have for the 24

damage their plants would cause. It's basically a 25


74

scheme, they pay into a pool. The problem is that 1

ceiling was set a very long time ago. It's totally 2

unrealistic in terms of the risk in just the value of 3

houses in areas that are covered by a plant like this. 4

When this plant was planned the population in the 5

area that its plume would cover probably wasn't 20 6

percent of what the population is now. That is I 7

think a valid environmental concern. The environment 8

in which this plant operates has changed because of 9

in-migration, population increase for all sorts of 10

reasons. Part of that's been discussed tonight in 11

terms of evacuation routes, would you be able to get 12

people out were there an accident. The roads haven't 13

changed very much, the population has. That I think 14

is a valid environmental concern that surely ought to 15

be addressed. 16

The question I ask about the money 17

liability is -- let's just go back to the Price 18

Anderson Act. The fact is that the nuclear industry 19

does not pay market rates for insurance to cover it 20

for the liabilities. This congressional act from way 21

back in the 1960s eliminates that need. Back then the 22

insurance industry didn't have the research to put a 23

price on what should the Limericks of the world have 24

to pay for a liability policy. I think there's plenty 25


75

of insurance industry experience now. So my question 1

would be if nuclear plants are so safe why do we need 2

the Price Anderson Act? 3

(Applause) 4

MR. BECKERMAN: I listened, I'm going to 5

switch subjects again. I listened to Mr. Gallagher 6

and I heard something I really didn't expect to hear. 7

He said that their studies said that this plant is 8

now safe to run for 60 years. That sounds to me like 9

advanced notice to the public that this isn't the 10

first renewal they're going to ask for on this plant. 11

Mr. Gallagher, are you going to ask for another one 12

20 years from now? 13

FACILITATOR BARKLEY: We haven't had any 14

licensee at this point in time ask for something 15

beyond that. 16

MR. BECKERMAN: You didn't make the 17

statement. Mr. Gallagher did. 18

FACILITATOR BARKLEY: I know and I'm not 19

going to have him address this from the audience. 20

This is a meeting with us. 21

MR. BECKERMAN: And I would like to 22

finally address an issue that the speaker on the cell 23

phone brought up. He talked about embrittlement of 24

concrete over the lifetime so far of the nuclear 25


76

reactor containment vessel. That's an internal 1

environmental matter. I don't know if it's quite in 2

the scope of what the NRC plans to talk about or plans 3

to look at, but something that I have not read about 4

at all is an NRC requirement for destructive testing. 5

For instance, if you want to know what a tree looks 6

like on the inside you put a borehole in it and you 7

pull a core sample out and you find out what that tree 8

looks like on the inside. If an engineer wants to 9

know what is the quality of the concrete that was 10

poured for a road -- I used to work for Florida 11

Department of Transportation -- they bore out a sample 12

and then you take a look at it. What I haven't heard 13

anything about except generalizations is has anybody 14

done any destructive even borehole testing of these 15

containment vessels and their support pourings to find 16

out has there been in fact any deterioration of the 17

concrete, the rebar and anything else that went in 18

there. The stuff that's buried in the concrete, the 19

wire, all of those things that are buried in the 20

concrete. If you haven't bothered to open that stuff 21

up since the plant was built how on earth do you know 22

what condition it's in? Shouldn't that be a 23

requirement to do some destructive, open the bottom 24

testing, go all the way through and make sure what you 25


77

think is there is what's there and in the condition 1

that it should be in to last for another 20 or 40 2

years? So these are questions that I'd like the NRC 3

to go into. I thank you very much for listening. 4

Overall it's been a very informative presentation by 5

both the proponents and people who have questions and 6

I thank you for the opportunity. I would like to see 7

a meeting like this occur at a bigger venue with more 8

notice. An example would be, as I've discussed with 9

Ms. Regner is it? 10

FACILITATOR BARKLEY: Regner, yes. 11

MR. BECKERMAN: I didn't have her name 12

correct. The Philadelphia Expo Center would be more 13

central to where the plume area for this plant is. 14

It's right off 422. This is not hard to get to, 15

that's not hard to get to. It's much more in the 16

center of the population. Thank you very much. 17

(Applause) 18


Mr. Cuthbert? Again, following Mr. Cuthbert's remarks 20

it'll be Jim Derr to wrap up the evening. 21

DR. CUTHBERT: Good evening. My name is 22

Dr. Lewis Cuthbert. I'm the president of ACE, the 23

Alliance for a Clean Environment. And my comments 24

this evening are going to differ from this afternoon 25


78

because they're going to be focusing on as a general 1

topic documented evidence. We've heard a lot of 2

assertions, assumptions and claims throughout the day 3

many of which would be very difficult to substantiate 4

in our experience. Based on an 11-year investigation 5

conducted by the Alliance for a Clean Environment we 6

have formed a conclusion that we are presenting to the 7

Nuclear Regulatory Commission today and that is very 8

simply that Limerick nuclear power plant must be 9

closed by the NRC, not re-licensed until 2049. And 10

that's based on a substantial body of evidence in 11

terms of documented environmental harms, threats and 12

risks that have in fact gotten into our air, our 13

water, our soil, our food, our milk and our children. 14

The evidence is not refutable. 15

So I'll be presenting as part of my 16

remarks tonight what I'm calling a short list of 14 17

reasons why the NRC may feel free to with more than 18

adequate justification deny this permit. And I'm 19

going to categorize each of them very briefly without 20

any further description or analysis. The evidence 21

comes from a variety of permits, official records and 22

reports, and Exelon's own renewal application which is 23

sizable by their own admission and in our experience 24

in taking a look at it. 25


79

The 14 items any of which in our judgment 1

should be adequate and sufficient to deny this permit 2

renewal include, number 1, radiation into air and 3

water from routine and accidental emissions. Number 4

2, major air pollution under health-based standards of 5

the Clean Air Act. A Title 5 permit being issued to 6

this facility means by definition that they are a 7

major air polluter under the federal Clean Air Act. 8

Number 3, Schuylkill River depletion and major 9

drinking water contamination. Keep in mind this is a 10

vital drinking water source for nearly 2 million 11

people from here to Philadelphia. Number 4, 12

radioactive groundwater contamination. Number 5, 13

radiation reporting levels increased dramatically 14

after the Fukushima Japan disaster. Number 6, 15

documented alarming cancer increases especially in our 16

children since Limerick started operating. Number 7, 17

deadly high-level radioactive wastes that are packed 18

in vulnerable fuel pools on this site and they are in 19

fact unprotected. They are above ground and 20

unprotected. Number 8, lax fire safety regulations 21

and multiple violations. Number 9, accidents and 22

leaks from corroding, deteriorating equipment plus 23

miles of buried pipes and cables. Many problems and 24

shutdowns have already occurred at this facility in 25


80

its first 26 years of operation. They are a matter of 1

record. Number 10, increased risk of meltdowns from 2

more frequent and stronger earthquakes and other 3

natural disasters such as tornadoes and floods, not to 4

mention mechanical failures. Number 11, threats from 5

unguarded terrorist attacks with planes and missiles 6

and a new threat, cyber attacks. Fuel pool are 7

vulnerable to attack. 8

Number 12, one that I think probably 9

should jump to the head of the list for the NRC based 10

on a lot of comments from a lot of other analysts and 11

elected officials, the need for an updated evacuation 12

plan and increased EPZ, a 10-mile radius. This plan 13

is seriously outdated. It is by many expert's 14

observations fatally flawed. There will be no 15

evacuation in the event of a worst case scenario. 16

Several people spoke to that this evening. The 17

population in this area has increased more than 180 18

percent since 1980 to 2010, U.S. Census data. Updates 19

are obviously needed and they should be reasonable, 20

comprehensive, detailed and accommodate all of the 21

demographics from 1985 to today and from today until 22

as far out as the NRC is willing to license this 23

facility. 24

Number 13, increased cost to the public. 25


81

We've heard a little bit about this this evening, more 1

cancers, more illnesses, more emergency room visits, 2

more hospitalization from increased PM-10. Massive 3

research on what particulate matter in terms of PM-10 4

does to human beings. And there are a few other 5

things that contribute to those visits. The costs are 6

astronomical. One case that Donna mentioned, $2.2 7

million for a childhood cancer case. You do the math. 8

And number 14, the last item on my list. 9

We have had 26 years of insults to our environment, 10

and I choose that word purposely, insults to our 11

environment and costly nuclear power. We can replace 12

it with safe, clean, renewable energy before 2029. 13

That is a matter of scientific fact. 14

It is a scientific certainty that harms, 15

threats and risks to our environment and to our 16

community will increase continuously daily until 17

Limerick's current operating licenses expire in 2029. 18

It would be both unethical and irresponsible for the 19

NRC to cavalierly approve a license renewal without 20

the most rigorous review and justification in the 21

history of this agency. NRC, you have a rare 22

opportunity before you that most people and agencies 23

never are afforded. It's called a do-over, a chance 24

to correct a litany of mistakes and errors associated 25


82

with this facility and with your agency since 1985. 1

Twentieth century technology and infrastructure are no 2

longer sufficiently reliable for any of you to assure 3

us that there is nothing to fear and nothing about 4

which to be concerned. Denial of documented evidence 5

is no longer an option. We'll be submitting 6

additional packets of research documentation and 7

evidence tonight along with my comments which will 8

compliment what I did earlier today. The major 9

categories that you'll be getting for additional 10

reading and review, meltdown threats, evacuation 11

plans, Exelon's inaccurate and unsubstantiated claims 12

and a criticism of the NRC's oversight track record in 13

this community. Thank you very much and please accept 14

this for review. 15

(Applause) 16

FACILITATOR BARKLEY: Okay, thank you, I 17

will. Thank you. Mr. Derr? 18

MR. DERR: Good evening. I thought I 19

would add some comments just to make sure my 20

understanding is that this is essentially the NRC's 21

opportunity of listening for things specifically to be 22

included in the environmental site review of the re-23

licensing. And just a few things which are question 24

marks that lots of folks in the community I think will 25


83

be interested in. Most of these have been touched on. 1

Mine water issue, better defining that 2

quality and flow particularly in light of the likely 3

pending changes in stormwater concerns and regulations 4

in the area. Adding that flow to the Schuylkill is 5

going to affect all the municipalities around here who 6

have to deal with stormwater. 7

The emergency planning is an area which 8

needs to be seriously looked at. Hard and soft 9

infrastructure on that. Hopefully that's something 10

which is part of the ongoing operational requirements 11

for periodic review and update since obviously this is 12

not a static environment we live in. That has to be 13

changed on an ongoing basis. And then to -- I'm sure 14

that the generic plan includes a pretty good 15

discussion of fuel storage long-term and short-term 16

onsite but certainly the site-specific fuel storage 17

considerations. And I want to second the comments by 18

Mr. Ely of review of records of non-conformances and 19

anything that was done is part of the initial 20

construction record. And basically that's -- those 21

are the things that we're going to be looking for a 22

better understanding of. Thank you. 23

(Applause) 24

FACILITATOR BARKLEY: I did have one last 25


84

request for an individual to speak. She promises 1

she'll only be two minutes so we'll have her up and 2

then we'll wrap up the meeting. Thank you. 3

MS. CONFER: Hi, my name is Traci Confer. 4

I'm with Energy Justice Network. We support clean 5

energy which we do not believe nuclear is. I would 6

like to put our name behind all of Buzz Cuthbert's 7

comments and I want to add that I want the NRC to look 8

into potential water depletion issues from shale gas 9

fracking upriver in both rivers. I also think that it 10

would be very prudent to put a lot of attention on 11

terrorist attacks on the fuel pools. And those are my 12

primary comments. Thank you for your time. 13

(Applause) 14


With that I'd like to have Lisa Regner come up for a 16

minute and give closing remarks. 17

MS. REGNER: I just wanted to real quickly 18

thank our senior resident inspector who came out 19

tonight out of the goodness of her heart. She does 20

not get paid for this. Jo, would you mind standing 21

up? 22

(Applause) 23

MS. REGNER: Thank you. This is one of 24

the NRC inspectors who works at the plant day in and 25


85

day out. She's onsite, she watches these guys like a 1

hawk and she's there to help keep you all safe. So 2

thank you for coming out tonight, Jo. If you would 3

also pass on my thanks to Nicole as well who was here 4

at the 2:00 session. She's also a resident inspector 5

who lives in the community and works at the plant 6

every day. Are there other regional people here that 7

wouldn't mind standing up? Anybody I missed? Oh, 8

Nancy McNamara is in the back. She is our state 9

liaison officer. Thank you for coming out, Nancy. 10

Anybody else? Thank you again to everyone for coming 11

out tonight, taking time away from your families to 12

provide environmental comments and look for the 13

Environmental Impact Statement where we'll address 14

your comments. Anything else? Anybody else? Rich, 15

thank you. 16

MR. ELY: One question. You're saying the 17

-- 18

MS. REGNER: License renewal application? 19

Yes, sir. 20

MR. ELY: Is that the final version? 21

MS. REGNER: Right. Right. There are 22

additional on the reviewer copies there's some 23

additional data that is -- some of it's publicly 24

available, some of it's not publicly available. But 25


86

and there are all kinds of drawings that the reviewers 1

use to look at those systems that are appropriate for 2

license renewal. There's a lot of extra information 3

that the public really didn't need, okay? But if 4

there is -- well, if there's -- okay. All right, yes, 5

I hear what you're saying. I'm sorry. You know, that 6

I didn't think you'd be interested in, can I put it 7

that way? 8

MR. ELY: The general public might not 9

have -- it might not be for them to see. Perhaps some 10

of them, it might not be -- for them to understand. I 11

don't know. But I wouldn't say that -- 12

MS. REGNER: If you want me to go into 13

details of the other material that's on the disk 14

that's for the reviewers I'd be happy to go over that. 15

And if it's publicly available I'd be happy to send 16

it to you. Okay? And you have my email and phone 17

number, right? Okay. I've got the card for you. 18

Anything else? 19

FACILITATOR BARKLEY: Okay, with that I 20

very much appreciate your patience. We actually had 21

15 total speakers tonight, the same number we had this 22

afternoon. I tried to give everyone a fair chance to 23

speak their full mind so that's why we ran a little 24

long but hopefully that was considered fair to all 25


87

members of the audience. So with that I'd like to 1

wrap up this meeting. Thanks very much. 2

(Applause) 3

(Whereupon, the foregoing matter went off 4

the record at 9:14 p.m.) 5

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23

Limerick Generating Station License Renewal Process

and

Environmental Scoping Meeting

September 22, 2011

Meeting Ground Rules

Rich Barkley, PE, Nuclear & Environmental Engineer

Meeting Facilitator

Please sign up on a blue speaker card if you’d like to speak

To be fair, the amount of time allotted will be limited and based on the number of speakers who sign up

I will call three speakers at a time to allow adequate time to prepare and to get to the microphone

The speakers initially called will alternate between elected officials and members of the public

2

Meeting Ground Rules

Please silence all cell phones!

Please speak clearly into the microphone, your remarks are being transcribed

Please do not interrupt the speaker or speak when not at the microphone

Written comments are welcome during and after this meeting – please give them to Lisa Regner

Please see me if you have questions or concerns regarding the conduct of this meeting

3

Purpose of Today’s Meeting

Provide overview of license renewal review process Safety review Environmental review

Receive public input on environmental review

4

NRC’s Governing Statutes – Atomic Energy Act – National Environmental Policy Act (NEPA)

NRC’s Mission

– Protect Public Health and Safety – Promote Common Defense and Security – Protect Environment

NRC Regulatory Oversight

5

License renewal application received on June 22, 2011

Unit 1 license expires October 26, 2024 Unit 2 license expires June 22, 2029

Limerick License Renewal

6

Acceptance/Sufficiency review Review contents of application

Technical information Technical Specifications Environmental Report

Docket

Docketing and Sufficiency of Application

7

Current Safety Performance http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/index.html

Emergency Planning

Security

Ongoing Regulatory Oversight

8

NRC Response to Fukushima

The NRC’s response to Fukushima is as a current operating issue

Increased inspections at operating facilities NRC NearTerm Task Force issued its report on July 12 Continued operations and continued licensing activities do not

pose an imminent risk to public health and safety

Staff paper on prioritization of task force recommendations due October 3

More information: http://www.nrc.gov/japan/japan-info.html

9

License Renewal Process

Environmental Review

NRC Renewal Decision

License Renewal Application

submitted to NRC

Safety Review

Review by ACRS

Hearings*

Consultation and Comment

* If a Request for Hearing is Granted 10

The ongoing regulatory process is adequate to ensure the safety of all currently operating plants

The same plant operating rules apply

during the renewal term – NRC applies additional conditions for

aging management

License Renewal Safety Principles

11

Safety Review Focus

Safety review focus is on the effects of aging on: – Safetyrelated systems, structures, and components

(SSCs) – Nonsafetyrelated SSCs which, if they failed, could

affect safetyrelated SSC functions – SSCs relied upon for compliance with regulations for:

• Fire protection • Environmental qualification • Pressurized thermal shock • Anticipated transients without scram • Station blackout

Safety review is to determine if aging effects will be effectively managed

12

Technical review by NRC staff – Review application and supporting

documentation – Onsite audits – Issue Safety Evaluation Report

Onsite inspections by NRC staff Independent review by the Advisory

Committee on Reactor Safeguards

Safety Review Process

13

14

Application Received June 22, 2011 Notice of Opportunity for Hearing August 24 Notice of Intent for Scoping August 26 Environmental Scoping Meeting September 22 Hearing Opportunity Closes October 24 Scoping Comments Due October 28 SER with Open Items July 2012 ACRS Subcommittee Meeting September 2012 Final SER Issued January 2013 ACRS Full Committee Meeting February 2013 Commission Decision (without hearing) April 2013

Safety Review Milestones (tentative)

National Environmental Policy Act (NEPA) – Informs Federal decision making – Public disclosure of environmental

impacts and other considerations NRC’s Environmental Regulations 10 CFR Part 51 Staff prepares an Environmental

Impact Statement

Environmental Review (10 CFR Part 51)

15

Staff Evaluates Impacts to Resources

– Fish and Wildlife – Water and Air Resources – Historical or Cultural

Resources – Taxes, Community

Development, Environmental Justice

– Human Health – Land Use

EIS

Environmental Impact Statement

State Seal

16

http://www.pgc.state.pa.us/�

http://www.pgc.state.pa.us/�

Scoping Process Generic Environmental Impact Statement http://www.nrc.gov/readingrm/doccollections/nuregs/staff/sr1437/

Sitespecific Supplemental Environmental Impact Statement New and significant information on generic

conclusions reached in the GEIS

Environmental Review (10 CFR Part 51)

17

Scoping and Public Involvement

What is unique about your community?

What local environmental issues should the NRC examine?

What reasonable alternatives are appropriate for the area?

18

Role of Public Comments Environmental Review

License Renewal Decision

SEIS

Regional Inspections

Safety Evaluation

Report

Hearing*

*If a Request for Hearing is Granted

Advisory Committee on Reactor Safeguards Independent Review

Public Comments on Environmental Review

License Renewal Application

19

How to Submit Comments on the Environmental Review

Online using the Federal Rulemaking Web Site: At http://www.regulations.gov Enter Keyword or ID:

By fax (reference Limerick license renewal):

RADB at 3014923446

Comments must be submitted by October 28

NRC-2011-0166

20

By mail (please reference Limerick license renewal):

Ms. Cindy Bladey Chief, Rules, Announcements, and Directives Branch Office of Administration, Mail stop: TWB05B01M US Nuclear Regulatory Commission Washington, DC 205550001

In person at NRC Headquarters

Comments must be submitted by October 28

How to Submit Comments on the Environmental Review

21

Application Received June 22, 2011 Notice of Opportunity for Hearing August 24 Notice of Intent for Scoping August 26 Environmental Scoping Meeting September 22 Hearing Opportunity Closes October 24 Scoping Comments Due October 28 Draft SEIS Issued August 2012 Draft SEIS Public Meeting September 2012 Draft SEIS Comments Due October 2012 Final SEIS Issued February 2013

Environmental Review Milestones

22

Project Manager Information

Lisa Regner (800) 3685642 ext. 1906 [email protected] Robert Kuntz (800) 3685642 ext. 3733 [email protected]

23

Where to view documents Documents located at:

• Pottstown Regional Pubic Library 500 East High Street Pottstown, PA 194645656

• Royersford Free Public Library 200 South 4th Avenue Royersford, PA 194682548

Documents can be viewed on the NRC’s Web site: www.nrc.gov/reactors/operating/licensing/renewal/applications.html

24

Limerick Generating Station License Renewal

Environmental Scoping Comments

Links to Relevant Information

Limerick License Renewal Website: http://www.nrc.gov/reactors/operating/licensing/renewal/applications/limerick.html License Renewal Fact Sheet: http://www.nrc.gov/reading-rm/doc-collections/fact-sheets/fs-reactor-license-renewal.pdf Information on the NRC’s license renewal process can be found at: http://www.nrc.gov/reactors/operating/licensing/renewal.html NRC Response To Japan Accident: http://www.nrc.gov/japan/japan-info.html Japan Task Force Report: http://pbadupws.nrc.gov/docs/ML1118/ML111861807.pdf Emergency Preparedness Fact Sheet: http://www.nrc.gov/reading-rm/doc-collections/fact-sheets/fs-emerg-plan-prep-nuc-power.pdf Seismic Issues for Nuclear Power Plants Fact Sheet: http://www.nrc.gov/reading-rm/doc-collections/fact-sheets/fs-seismic-issues.pdf Nuclear Insurance and Disaster Relief Funds Fact Sheet: http://www.nrc.gov/reading-rm/doc-collections/fact-sheets/funds-fs.pdf To subscribe to all outgoing public correspondence on Limerick Generating Station (and other operating reactors), go to: http://www.nrc.gov/public-involve/listserver/plants-by-region.html

• Enter your name and email address • Check the box for Limerick in Region I (and any other plants you are interested in) • Hit ‘Subscribe,’ at the bottom of the page

Links to Relevant Information

Limerick License Renewal Website: http://www.nrc.gov/reactors/operating/licensing/renewal/applications/limerick.html License Renewal Fact Sheet: http://www.nrc.gov/reading-rm/doc-collections/fact-sheets/fs-reactor-license-renewal.pdf Information on the NRC’s license renewal process can be found at: http://www.nrc.gov/reactors/operating/licensing/renewal.html NRC Response To Japan Accident: http://www.nrc.gov/japan/japan-info.html Japan Task Force Report: http://pbadupws.nrc.gov/docs/ML1118/ML111861807.pdf Emergency Preparedness Fact Sheet: http://www.nrc.gov/reading-rm/doc-collections/fact-sheets/fs-emerg-plan-prep-nuc-power.pdf Seismic Issues for Nuclear Power Plants Fact Sheet: http://www.nrc.gov/reading-rm/doc-collections/fact-sheets/fs-seismic-issues.pdf Nuclear Insurance and Disaster Relief Funds Fact Sheet: http://www.nrc.gov/reading-rm/doc-collections/fact-sheets/funds-fs.pdf To subscribe to all outgoing public correspondence on Limerick Generating Station (and other operating reactors), go to: http://www.nrc.gov/public-involve/listserver/plants-by-region.html

• Enter your name and email address • Check the box for Limerick in Region I (and any other plants you are interested in) • Hit ‘Subscribe,’ at the bottom of the page

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